NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8254-BC

NON-MEMBER:

Peter Helmut Stüdemann
AKA Peter Stuedemann
AKA Pete Kosto

CBOT RULE VIOLATIONS:

Rule 432. - General Offenses
It shall be an offense:
B.1. to engage in fraud or bad faith;

C. to engage in dishonest conduct;

G. to prearrange the execution of transactions in Exchange products for the purpose of transferring equity between accounts;

L.1. to fail to appear before the Board, Exchange staff or any investigative or
hearing committee at a duly convened hearing, scheduled staff interview or in connection with any investigation;

L.3. to fail to produce any books or records requested by duly authorized
Exchange staff, in the format and medium specified in the request, within 10 days after such request is made or such shorter period of time as determined by the Market Regulation Department in exigent circumstances.

Rule 576 - Identification of Globex Terminal Operators
In no event may a person enter an order or permit the entry of an order by an individual using a user ID other than the individual’s own unique user ID.

FINDINGS:

On November 28, 2012, a panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“BCC”) took disciplinary action against Peter Stüdemann (“Stüdemann”), a non-member of CME Group Exchanges, who has held himself out to be a German National and uses the names Peter Stuedemann and Pete Kosto. On March 8, 2013, a Hearing Panel Chair of the CBOT BCC found that Stüdemann had failed to file an answer to charges issued against him by a panel of the CBOT Probable Cause Committee. The Hearing Panel Chair accordingly ruled that the charges issued against Stüdemann were deemed admitted, and through this admission, Stüdemann had forfeited his right to a hearing on the merits of the charges. Pursuant to CBOT Rule 407 and 408, a penalty hearing was held before a Panel of the CBOT BCC (“Panel”) on March 14, 2013, related to these admitted charges. The Panel found Stüdemann guilty of having committed the admitted charges, which alleged that Stüdemann (both individually and through three websites he controls - www.options-selling.com, www.dow-trading.com and www.t-bonds-trading.com) solicited services to manage and/or advise the trading of various commodity options contracts for individual customer accounts over the CME Globex electronic trading platform (“Globex”). In doing so, Stüdemann fraudulently represented through www.options-selling.com that he was a registered commodity trading advisor (“CTA”) under the Commodity Exchange Act even though no such registration is currently active with the National Futures Association. The Panel found that in so doing, Stüdemann violated CBOT Rule 432.B.1.

As a result of his solicited services via the internet, Stüdemann was able to manage and advise individual customer accounts. From January 2011 through February 6, 2012, Stüdemann orchestrated a scheme whereby he knowingly and intentionally executed, and/or directed the execution of, trades in 30-Year U.S. Treasury Bond options and Wheat options for his customers’ accounts over Globex that he illegally prearranged for the purpose of passing money from those customer accounts to his personal account and/or an account with which he had financial interest. As a result, Stüdemann misappropriated over $10,800 in customer funds. The Panel found that in so doing, Stüdemann violated CBOT Rules 432.C. and 432.H.

The Panel found that Stüdemann entered orders over Globex using a TAG 50 ID other than his own in violation of CBOT Rule 576.

The Panel further found that Stüdemann failed to produce records, documents and information requested by Market Regulation within 10 days of its request in violation of CBOT Rule 432.L.3

Finally, the Panel found Stüdemann failed to participate by phone in a scheduled staff interview in connection with this investigation in violation of CBOT Rule 432.L.1.

PENALTY:

In accordance with its findings, the Panel ordered Stüdemann be permanently barred from: (1) applying for membership at any exchange owned, controlled, or operated by CME Group Inc.; (2) directly or indirectly accessing, placing orders, or executing trades on any trading or clearing platform owned, controlled, or operated by CME Group Inc., including, but not limited to, the CME Globex electronic trading platform, CME ClearPort and CME Direct; and (3) affiliating with any Member of any CME Group Exchange in connection with business conducted on or subject to Exchange Rules.

EFFECTIVE DATE:

March 18, 2013.