NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

STEPHEN DUGGAN

CBOT RULE VIOLATIONS:

Rule 432. General Offenses (in part)

It shall be an offense:

B.2. to engage in conduct or proceedings inconsistent with just and equitable principles of trade;

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange;

T. to engage in dishonorable or uncommercial conduct.

FINDINGS:

Pursuant to an offer of settlement in which Stephen Duggan (“Duggan”) neither admitted nor denied the rule violations upon which the penalty is based, and after voluntarily submitting himself to the jurisdiction of the Exchange for purposes of resolving the matter, on June 3, 2015, a Panel of the CBOT Business Conduct Committee (“Panel”) found that during August 2012, Duggan engaged in a pattern of activity wherein he entered orders in the Soybean and Wheat futures markets without the intent to trade. The Panel specifically found that Duggan placed a small order to sell (buy) in the futures contract market on the CME Globex electronic trading platform (“Globex”). Duggan subsequently entered multiple larger-sized buy (sell) orders at various book levels at or near the best bid (offer) on Globex to create the appearance of an imbalance in buy/sell pressure. Once the small order began trading, Duggan canceled the larger-sized orders. The Panel further found that Duggan entered the larger-sized orders for the purpose of inducing other market participants to trade against the small orders resting on the other side of the order book. The Panel concluded that Duggan thereby violated CBOT Rules 432.B.2., 432.Q., and 432.T.

PENALTY:

In accordance with the settlement offer and taking into consideration Duggan’s disciplinary history and financial condition when levying the sanction, the Panel ordered Duggan to serve a two year suspension of access to any CME Group Inc. trading floor and of direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group, Inc., including CME Globex beginning on the effective date and running for a period of two years from completion of the two year suspension of trading access ordered by the BCC in COMEX 11-8466-BC and NYMEX 12-9030-BC.

EFFECTIVE DATE:

June 5, 2015