NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 10-7844-BC

MEMBER:

CHRISTOPHER BRUNO (CCB)

CBOT RULE  VIOLATION:

534. WASH TRADES PROHIBITED

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

FINDINGS:

Pursuant to an offer of settlement in which Christopher Bruno neither admitted nor denied the rule violation upon which the penalty is based, on June 6, 2012, a Panel of the CBOT Business Conduct Committee found that on one or more occasions between March 1, 2011 and July 15, 2011, Bruno entered a series of bids and offers in the 5-Year U.S. Treasury Note futures market on the CME Globex® electronic trading platform when he knew, or reasonably should have known that his bids and offers would match opposite each other, and therefore, would not be exposed to market risk. The panel found that in doing so, Bruno violated CBOT Rule 534.

PENALTY:

In accordance with the offer of settlement, the Panel fined Bruno $20,000, suspended his membership privileges, access to the trading floor and his direct access to any electronic trading or clearing platform owned or controlled by CME Group 10 business days. The suspension shall begin on the effective date below.

EFFECTIVE DATE:

June 8, 2012