NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 08-03916-BC

MEMBER:

JOHN RYAN FINN

CME RULE VIOLATIONS:

Rule 530. PRIORITY OF CUSTOMERS’ ORDERS

A member shall not buy (sell) a futures contract, buy (sell) a call option or sell (buy) a put option for his own account, an account in which he has a direct or indirect financial interest, or an account over which he has discretionary trading authority when he is in possession of an executable order for another person to buy (sell) a futures contract, buy (sell) a call option or sell (buy) a put option in the same product, regardless of the venue of execution. All contract months in a given futures product and all options on the futures product, in addition to any corresponding alternative sized (mini or micro) futures or options contracts on a given product, shall be considered the same product for the purposes of this rule.

Rule 531.A. TRADING AGAINST CUSTOMERS’ ORDERS PROHIBITED

No person in possession of a customer order shall knowingly take, directly or indirectly, the opposite side of such order for his own account, an account in which he has a direct or indirect financial interest, or an account over which he has discretionary trading authority.

FINDINGS:

After a full evidentiary hearing on the merits of the case on January 26, 2011, a Panel of the CME Business Conduct Committee (“Panel”) found that on one or more occasions between March 20, 2008 and October 31, 2008, Finn indirectly traded against his customer orders. The Panel concluded that in so doing, Finn violated CME Rule 531.

The Panel further found that on one or more occasions between May 28, 2008 and September 15, 2008, Finn traded ahead of his customer orders. In so doing, Finn violated CME Rule 530.

PENALTY:

Based on the record and the Panel’s findings and conclusions, the Panel ordered Finn to pay a fine in the amount of $40,000. The Panel further barred Finn from membership on any CME Group Inc. exchange for a period of one year and barred him from direct access to the CME Globex electronic trading platform for a period of one year. The membership and direct access bars begin on the effective date below and continue through and include April 20, 2012.

EFFECTIVE DATE:

April 21, 2011