NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 08-05039-BC & CME 08-03909-BC

MEMBER:

WALTER B. POSNER (WBP)

CME RULE VIOLATIONS:

432. General Offenses

It shall be an offense:

…..

T. To engage in dishonorable or uncommercial conduct.

FINDINGS:

Pursuant to an offer of settlement in which Walter Posner neither admitted nor denied the rule violation upon which the penalty is based, on September 21, 2011, a Panel of the CME Business Conduct Committee found that on October 24, 2008, while in the Standard and Poor’s 500 Stock Price Index futures pit, Posner knowingly put trades into three other members that had not been competitively executed. The Panel concluded that in so doing, Posner violated CME Rule 432.T.

The Panel further found that on June 5, 2008, in the course of a business dispute, Posner made an unprofessional comment to another member on the trading floor. The Panel concluded that in so doing, Posner violated CME Rule 432.T.

PENALTY:

In accordance with the settlement offer, the Panel fined Posner $25,000 and suspended his membership privileges, access to any CME Group trading floor, and direct access to any CME Group electronic trading or clearing platform for 30 business days from September 23, 2011 through November 3, 2011, inclusive.

EFFECTIVE DATE:

September 23, 2011