NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 08-00096-BC

MEMBER:

ALAN CASKEY

CBOT RULE VIOLATIONS:

(legacy) Rule 500.00 Inequitable Proceedings

It shall be an offense against the Exchange to.... engage in…. conduct or proceedings inconsistent just and equitable principles of trade….

(legacy) Rule 501.00 Fictitious Transactions

It shall be an offense against the Exchange to create fictitious transactions or to give an order for the purchase or sale of futures or options the execution of which would involve no change in ownership, or to execute such an order with knowledge of its character.

FINDINGS:

Pursuant to an offer of settlement in which Alan Caskey neither admitted nor denied the rule violations upon which the penalty is based, on October 26, 2010, a Panel of the CBOT Business Conduct Committee found that on numerous occasions between January 2007 and December 2007, Caskey improperly assigned trades and recorded fictitious trades post-execution in order to reallocate profitable trades from his own trading account into his son and son-in-law’s trading accounts and, in addition, from 2008 through 2010 improperly transferred trades from his account to his son and son-in-law’s accounts;. In so doing, the Panel found that Caskey violated legacy CBOT Rule 500.00 and Rule 501.00.

PENALTY:

In accordance with the settlement offer the Panel fined Caskey $50,000 and suspended his membership privileges, access to any CME Group trading floors, and direct access to any CME Group electronic trading or clearing platform for 30 business days, beginning October 28, 2010, and continuing through December 9, 2010, inclusive.

EFFECTIVE DATE:

October 28, 2010