NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Stephen Bethell

CME RULE VIOLATIONS:

Rule 532 Disclosing Orders Prohibited

No person shall disclose another person's order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. An order for pit execution is not considered public until it has been bid or offered by open outcry.

(LEGACY) Rule 533 Simultaneous Buy and Sell Orders for Different Beneficial Owners (in part)

On the Globex platform, opposite orders for different beneficial owners that are simultaneously placed by a party with discretion over both accounts may be entered into the Globex platform provided that one order is exposed for a minimum of 5 seconds in the case of futures orders or a minimum of 15 seconds in the case of options orders. An order allowing for price and/or time discretion, if not entered immediately upon receipt, may be knowingly entered opposite another order entered by the same Firm only if this other order has been entered immediately upon receipt and has been exposed on the Globex platform for a minimum of 5 seconds for futures orders or a minimum of 15 seconds for options orders.

FINDINGS:

Pursuant to an offer of settlement in which Stephen Bethell neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on October 25, 2022, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that on February 24, 2020, Bethell, while soliciting counterparties for a buy order in the March 2020 Eurodollar 98.50 Call Options, sent instant messages to separate message rooms visible to two separate customers, which in the process disclosed non-public order information, including the instrument, side of market, and price of a potential order. Bethell’s disclosure had the effect of inducing orders from those two customers.

Additionally, on February 26, 2020, Bethell and another trader at the same firm placed opposite orders for different beneficial owners in the June 2020 Eurodollar 9887-9962 Call Options Spread market without exposing one of the orders on Globex for a minimum of 15 seconds.

The Panel concluded that Bethell thereby violated CME Rules 532 and 533.

PENALTY:

In accordance with the settlement offer, the Panel ordered Bethell to pay a fine in the amount of $10,000 and suspended Bethell 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 for 5 business days, beginning on the effective date below, and continuing through and including November 2, 2022.

EFFECTIVE DATE:

October 27, 2022