NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Jaeho Lee

CME RULE VIOLATIONS:

Rule 539.A. Prearranged, Pre-Negotiated and Noncompetitive Trades Prohibited (in part)

No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction.

Rule 576. Identification of Globex Terminal Operators (in part)

Each individual must use a unique operator ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using an operator ID other than the individual’s own unique operator ID.

FINDINGS:

Pursuant to an offer of settlement in which Jaeho Lee neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on December 14, 2023, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that on numerous occasions between February 8, 2022, and April 14, 2022, Lee prearranged the execution of numerous trades in the E-mini Nasdaq-100 options on futures market. Specifically, Lee coordinated the order entry in his accounts and his wife’s accounts in order to ensure that his orders traded opposite the orders his wife entered in separate accounts. The Panel also found that Lee utilized a unique operator ID other than his own to enter orders.

The Panel concluded that Lee thereby violated CME Rules 539.A. and 576.

PENALTY:

In accordance with the settlement offer, the Panel ordered Lee to pay a $15,000 fine in connection with this case and NYMEX 22-1592-BC and CBOT 22-1592-BC ($5,000 of which is allocated CME). The Panel also suspended Lee 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 10- business days, beginning on trade date December 18, 2023, and continuing through and including trade date January 2, 2024.