NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Shawn Branstetter

CBOT RULE VIOLATION:

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 Shawn Branstetter neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on December 7, 2023, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on multiple occasions between January 1, 2021, through January 31, 2022, Branstetter entered buy and sell orders in various KC HRW Wheat, Wheat, Soybean, and Corn futures contracts that matched between two accounts with common beneficial ownership, or the same account. The Panel also found that, although Branstetter intended to place limit orders followed by stop limit orders, he instead placed resting orders on one side of the market followed by limit orders at or through his resting order’s price. Branstetter reasonably should have known that the execution of the orders would achieve a wash result.

The Panel concluded that Branstetter thereby violated CBOT Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Branstetter to pay a $10,000 fine and suspended him 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 trade date December 22, 2023.

EFFECTIVE DATE:

December 11, 2023