NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8039-BC

NON -MEMBER:

Bob de Wit

CBOT RULES:

CBOT Rule 432. General Offenses

It shall be an offense:

C. to engage in dishonest conduct

CBOT Rule 539.A. General Prohibition

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

FINDINGS:

Between December 7, 2009 and May 2, 2011, Bob de Wit, a trader at ING Bank N.V., executed a total of 110 trades for 19,245 contracts on the CME Globex electronic platform for his wife’s (Nurhayat de Wit), personal account at Interactive Brokers, LLC, directly opposite an ING Bank account; the purpose being to pass $268,343.75 from ING Bank to Nurhayat de Wit.

PENALTY:

A permanent ban from :
a. Any CME Group exchange membership and privileges;
b. Direct and indirect access and use of any CME Group trading floor, electronic trading or clearing platform owned or operated by any CME Group exchange; and a
c. Affiliation with, employment by, or association with a broker association, guaranteed introducing broker, Member or affiliate of a Member registered with any CME Group exchange, trading platform or clearing platform.

EFFECTIVE DATE:

December 31, 2012