NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Dan Patrick Sobolewski

CBOT RULE VIOLATIONS:

Rule 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 Dan Patrick Sobolewski (“Sobolewski”) neither admitted nor denied the rule violations upon which the penalty is based, on July 22, 2015, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that it had jurisdiction over Sobolewski pursuant to Rules 400 and 402, as the conduct occurred while Sobolewski was an employee of a CBOT clearing member firm. The Panel further found that on September 26, 2013, Sobolewksi submitted large-quantity opposing customer orders for accounts with common beneficial ownership in the 10-Year USD Deliverable Interest Rate Swap futures market via open outcry. Sobolewski knew that the orders were for accounts with common beneficial ownership and mistakenly believed the orders could trade opposite each other as long as they were placed into the pit and bid and offered by the pit broker three times. In submitting the opposing buy and sell orders for execution in this manner, Sobolewski knew that the orders could trade opposite each other and avoid taking a bona fide market position exposed to market risk. The Panel concluded that Sobolewski thereby violated CBOT Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Sobolewski to pay a fine in the amount of $15,000, and to have his access to all CME Group trading floors and direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group suspended for a period of five business days. The suspension shall run from July 27, 2015, through July 31, 2015, inclusively.

EFFECTIVE DATE:

July 24, 2015