NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Andrew Meehan

CME RULE VIOLATIONS:

Rule 534 Wash Trades Prohibited

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

FINDINGS:

Pursuant to an offer of settlement in which Andrew Meehan 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 multiple occasions between January 1, 2020, and August 31, 2020, Meehan entered buy and sell orders in various E-mini S&P 500 futures that matched between two accounts with common beneficial ownership. Meehan entered the orders to hedge overnight exposure. Meehan reasonably should have known that the execution of the orders would result in a prohibited wash result.

The Panel concluded that Meehan thereby violated CME Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Meehan to pay a $10,000 fine and suspended Meehan from access to any trading floor owned or controlled by CME Group and 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 November 9, 2022.

EFFECTIVE DATE:

October 27, 2022