NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Brendan Ryan

CME RULE VIOLATION:

Rule 532 Disclosing Order Prohibited (in part)

No person shall take action or direct another to take action based on non-public order information, however acquired.

FINDINGS:

Pursuant to an offer of settlement in which Brendan Ryan neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on March 22, 2023, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that on numerous occasions from January 6, 2021, through August 13, 2021, Ryan, a commodity pool operator employee, took action based on non-public order information. Specifically, Ryan became aware of his employer’s impending orders in E-Mini Nasdaq 100 futures and E-Mini S&P 500 futures when he overheard the portfolio manager disclose order instructions to another employee during a company-wide video chat, and then Ryan executed trades for his personal trading account based on that information. Ryan traded before his employer’s larger market-moving orders and, as a result of the activity, benefited $46,932.84.

The Panel concluded that as a result of the foregoing, Ryan violated CME Rule 532.

PENALTY:

In accordance with the settlement offer, the Panel ordered Ryan to pay a fine of $20,000, disgorgement of profits in the amount of $46,932.84, and suspended Ryan 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 a period of one year, beginning on the effective date below, and continuing through and including March 24, 2024.

EFFECTIVE DATE:

March 24, 2023