NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 09-05941-BC

MEMBER:

TIMOTHY QUINLIVAN (TQQ)

CME RULE VIOLATION:

536. RECORDKEEPING REQUIREMENTS FOR PIT, GLOBEX, AND
NEGOTIATED TRADES

A. General Requirements for Open Outcry Pit Trades

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Each member must maintain, and is accountable for, all other documents on which original trade information is recorded, whether or not such information is subsequently endorsed on an order ticket or entered into an approved electronic device.

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H. Retention of Records

Each member and member firm and employees of the foregoing must keep full, complete and systematic records, including records created or transmitted electronically, together with all pertinent data and memoranda, of all transactions relating to its business of dealing in commodity futures, options and cash transaction in accordance with CFTC Regulations 1.35. Such records must be retained for a minimum of five years in permanent form, and shall at all times be open to inspection by Exchange staff or any representative of the CFTC of the United States Department of Justice.

FINDINGS:

Pursuant to an offer of settlement in which Timothy Quinlivan neither admitted nor denied the findings and conclusions herein, on November 10, 2010 a Panel of the CME Business Conduct Committee found that Quinlivan failed to produce and/or maintain original brokerage cards for seven dates between June and September 2009. The Panel found that in so doing, Quinlivan violated CME Rules 536.A. and 536.H.

PENALTY:

In accordance with the settlement offer, the Panel fined Quinlivan $5,000.

EFFECTIVE DATE:

November 12, 2010