NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 07-TPR-18-BC

MEMBER:

PAUL PERLIN (PJP)

LEGACY CBOT REG. VIOLATION:

332.05 Card Collection

***
A member may correct any errors on trading documents by crossing out erroneous information without obliterating or otherwise making illegible any of the originally recorded information. Alternatively, with regard to trading cards only, a member may correct any errors by rewriting the trading card. However, if a trading card is rewritten to correct erroneous information, the member shall provide his clearing member with the top ply of the original trading card, or in the absence of plies, the original trading card, which has been subsequently rewritten, in accordance with the same collection schedule designated by the Exchange for trading documents relied upon for clearing purposes.

***
332.07 Accountability of Trading Documents

Each member executing transactions on the Floor of the Exchange, and his clearing member(s), shall establish and maintain procedures that will assure the complete accountability of all trading cards used in the execution of trades for the member’s personal account, whether or not the information on such trading cards is also entered into an approved electronic device.

***

FINDINGS:

Pursuant to an offer of settlement in which Paul Perlin neither admitted nor denied the findings, on March 31, 2010, a Panel of the CBOT Business Conduct Committee found that on February 1, 2007, Perlin failed to maintain original trading cards after rewriting transactions on new trading cards. The Panel found that in so doing, Perlin violated legacy CBOT regulations 332.05 and 332.07.

PENALTY:

In accordance with the settlement offer, the Panel fined Perlin $7,500.

EFFECTIVE DATE:

April 5, 2010