NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 08-02234-BC

NON-MEMBER:

DENNIS G. DINE JR.

CBOT RULE  VIOLATIONS:

Rule 533 Simultaneous Buy and Sell Orders for Different Beneficial Owners

…. On the Globex platform, opposite orders for different beneficial owners that are simultaneously placed by a party with discretion over both accounts may be entered into the Globex platform provided that one order is exposed for a minimum of 15 seconds in the case of options orders….

Rule 532. Disclosing Orders Prohibited

No person shall disclose another person’s order to buy and sell except to designated Exchange official….

FINDINGS:

Pursuant to an offer of settlement in which Dennis Dine neither admitted nor denied the rule violations upon which the penalty is based, on April 19, 2011, a Panel of the CBOT Business Conduct Committee found that on various occasions in 2008, Dine failed to wait the requisite 15 seconds before placing simultaneous buy and sell options orders in interest rate products and that on one occasion in 2009 he disclosed the existence of customer orders while relaying market information to another customer. The Panel found that in so doing Dine violated CBOT Rule 533 and Rule 532.

PENALTY:

In accordance with the settlement offer, the Panel fined Dine $15,000 and suspended his access to any CME Group trading floor and direct access to any CME Group electronic trading or clearing platform, for 5 business days, beginning April 21, 2011, and continuing through, April 28, 2011, inclusive.

EFFECTIVE DATE:

April 21, 2011