NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 08-02234-BC

NON-MEMBER:

JOHN P. MAHER

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….

Rule 542 Simultaneous Spread and Combination Transactions
…..

A. All spread or combination transactions in which all sides are acquired simultaneously must be for the same account….

FINDINGS:

Pursuant to an offer of settlement in which John Maher neither admitted nor denied the rule violations upon which the penalty is based, on April 5, 2011, a Panel of the CBOT Business Conduct Committee found that on various occasions in 2009, Maher failed to wait the requisite 15 seconds before placing simultaneous buy and sell options orders in interest rate products and on one occasion disclosed the existence of a customer order while relaying market information to another customer. The Panel also found that on April 9, 2009, Maher improperly resolved an error by allocating a spread leg executed on behalf on one customer to another customer. The Panel found that in so doing Maher violated CBOT Rule 533, Rule 532 and Rule 542.

PENALTY:

In accordance with the settlement offer, the Panel fined Maher $20,000 and suspended his access to any CME Group trading floor and direct access to any CME Group electronic trading or clearing platform, for 10 business days, beginning April 7, 2011, and continuing through April 20, 2011, inclusive.

 

EFFECTIVE DATE:

April 7, 2011