NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

David Hall

CME RULE VIOLATIONS:

Rule 575. Disruptive Practices Prohibited (In Part)

All orders must be entered for the purpose of executing bona fide transactions. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.

D. No person shall enter or cause to be entered an actionable or non-actionable message(s) with intent to disrupt, or with reckless disregard for the adverse impact on, the orderly conduct of trading or the fair execution of transactions.

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 David Hall neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on January 31, 2024, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that on July 2, 2021, in August 2021 Brazilian Real futures, and on January 27, 2022, in March 2022 E-mini Russell 2000 Index futures, Hall, with reckless disregard for the adverse impact on the orderly conduct of trading or the fair execution of transactions, entered aggressive buy orders without adequately considering the depth of the markets that far exceeded the quantity at the best offer and beyond. The orders traded immediately through multiple price levels and resulted in disruptive price movements and reversions. Further, Hall entered the orders using the operator ID assigned to his client.

The Panel thereby concluded that Hall violated CME Rules 575.D. and 576.

PENALTY:

In accordance with the settlement offer, the Panel ordered Hall to pay a $30,000 fine and suspended him 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 five business days. The suspension shall begin on trade date February 2, 2024, and continue through and include trade date February 8, 2024.