NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Richard Grzan Jr.

CBOT RULE VIOLATIONS:

Rule 575. Disruptive Practices Prohibited (in part)

All orders must be entered for the purpose of executing bona fide transactions. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.

D. No person shall enter or cause to be entered an actionable or non-actionable message(s) with intent to disrupt, or with reckless disregard for the adverse impact on, the orderly conduct of trading or the fair execution of transactions.

Rule 576. Identification of Globex Terminal Operators (in part)

Each individual must use a unique operator ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using an operator ID other than the individual’s own unique operator ID.

FINDINGS:

Pursuant to an offer of settlement in which Richard Grzan Jr. neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on August 10, 2022, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on multiple occasions between January 5, 2021, and September 17, 2021, in November 2021 and November 2022 Soybean futures, Grzan entered aggressive orders that greatly exceeded the quantity at the best bid and offer and beyond. The orders traded immediately through multiple price levels and resulted in disruptive price movements and reversions. Further, Grzan entered the orders using the operator ID assigned to his employer.

The Panel concluded that Grzan violated CBOT Rules 575.D. and 576.

PENALTY:

In accordance with the settlement offer, the Panel ordered Grzan to pay a $15,000 fine in connection with this case and companion case CME 21-1475-BC (of which $7,500 is allocated to CBOT) and suspended him from all direct and indirect access to any designated contract market, derivatives clearing organization, or swap execution facility owned or controlled by CME Group Inc. for 10 business days. The suspension shall begin on the effective date below and continue through and include August 25, 2022.

EFFECTIVE DATE:

August 12, 2022