NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Randy Chen

CBOT RULE VIOLATION:

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.

A. No person shall enter or cause to be entered an order with the intent, at the time of order entry, to cancel the order before execution or to modify the order to avoid execution.

FINDINGS:

Pursuant to an offer of settlement in which Randy Chen neither admitted nor denied the Rule violations or factual findings upon which the penalty is based, on September 22, 2022, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that between October 30, 2020, and June 1, 2021, Chen entered or caused to be entered orders with the intent, at the time of order entry, to cancel the orders before execution or to modify the orders to avoid execution in the December 2020 Ultra 30-Year Treasury Bond, March 2021 Ultra 30-Year Treasury Bond, June 2021 Ultra 30-Year Treasury Bond, June 2021 Ultra 10-Year Treasury Note, and September 2021 Ultra 10-Year Treasury Note futures markets. Specifically, Chen entered a large order or layered orders on one side of the market that he cancelled after receiving fills on smaller order(s) he entered on the other side of the market. The Panel concluded that Chen thereby violated CBOT Rule 575.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Chen to pay a $75,000 fine in connection with this case and companion cases CME 21-1449-BC and COMEX 21-1449-BC ($60,000 of which is allocated to CBOT) and to serve a six-month suspension from access to any trading floor owned or controlled by CME Group and from direct and indirect access to any designated contract market, derivatives clearing organization or swap execution facility owned or controlled by CME Group, beginning on the effective date below and continuing through and including March 27, 2023.

EFFECTIVE DATE:

September 26, 2022