NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Tanner Di Lello

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 violation 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 Tanner Di Lello neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on May 15, 2024, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that on February 6, 2023, Di Lello entered buy and sell orders in December 2027 Three-Month SOFR futures between two accounts of different entities with common beneficial ownership for the legitimate purpose of hedging the interest rate exposure in each. However, the orders traded against each other in part, and Di Lello knew or reasonably should have known that the execution of the orders would result in a prohibited wash result.

The Panel concluded that as a result of the foregoing, Di Lello violated CME Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Di Lello to pay a fine of $10,000 and suspended Di Lello 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 5 business days, beginning on the effective date below, and continuing through and including May 23, 2024.

EFFECTIVE DATE:

May 17, 2024