NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 08-05115-BC

NON-MEMBER:

JOHN CRATHERN

CME RULE VIOLATION:

539. PREARRANGED, PRE-NEGOTIATED AND NON-COMPETITIVE TRADES PROHIBITED

A. No person shall prearrange or pre-negotiate any purchase or sale or non-competitively execute any transaction.

FINDINGS:

Pursuant to an offer of settlement in which John Crathern neither admitted nor denied any rule violations upon which the penalty is based, on May 10, 2011, a panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee found that on September 25, 2008, Crathern prearranged or pre-negotiated the execution of a 2000-lot October 2008 Eurodollar Futures order with another non-member and by doing so, he violated CME Rule 539.A.

PENALTY:

In accordance with the offer of settlement, the Panel ordered John Crathern to pay a fine of $15,000. The panel further suspended Crathern’s direct access to any trading floor or electronic trading or clearing platform owned or operated by CME Group Inc., including CME Globex®, for 20 business days. Crathern’s suspension will run from May 12, 2011 through June 8, 2011 inclusive.

EFFECTIVE DATE:

May 12, 2011