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      • CBOT 10-4973-BC AND CBOT 10-5130-BC
      • Effective Date
      • 19 December 2014
    • MEMBER:

      James Czajkowski


      Rule 521 (“Requirements for Open Outcry Trades”)(in part)

      In open outcry trading, bidding and offering practices must at all times be conducive to the competitive execution of transactions. All open outcry transactions, including spread and combination transactions, shall be made openly and competitively in the pit designated for the trading of the particular transaction. No bid or offer shall be specified for acceptance by a particular trader.

      Rule 532. Disclosing Orders Prohibited (in part)

      No person shall disclose another person's order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. No person shall take action or direct another to take action based on non-public order information, however acquired.

      Rule 539.A (“Prearranged, Pre-Negotiated and Noncompetitive Trades Prohibited”) (in part)

      No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction.


      Pursuant to an offer of settlement in which James Czajkowski (“Czajkowski”) neither admitted nor denied the rule violations upon which the penalty is based, on December 17, 2014, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that it had jurisdiction over Czajkowski pursuant to Rules 400 and 402 as the conduct occurred while Czajkowski was a CBOT member, and that on one or more occasions in June 2010, July 2010, and April 2011, Czajkowski engaged in trades as a broker in the Corn Futures pit that were not competitively executed by open outcry. Specifically, in each instance Czajkowski executed trades that cleared opposite other traders in the Corn pit without bidding or offering openly to the pit. Further, on one occasion in June 2010, Czajkowski disclosed customer orders to another trader in the Corn pit. The Panel concluded that Czajkowski thereby violated CBOT Rules 521, 532, and 539.A.


      In accordance with the settlement offer, the Panel ordered Czajkowski to pay a fine of $30,000. The Panel also suspended Czajkowski for a period beginning on the effective date, lasting ninety days, from accessing all CME Group Inc. trading floors, and direct access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. The suspension shall run from December 19, 2014, through and including March 19, 2015.


      December 19, 2014