NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 09-06088-BC

NON-MEMBER:

ROBERT ZYGMUNT

CME RULE VIOLATION:

534 WASH SALES PROHIBITED

No person shall place for the same beneficial owner buy and sell orders for the same product and expiration month, and, for a put or call option, the same strike price, at or about the same time with the intent to avoid a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders placed for the same beneficial owner in the same product and expiration month, and, for a put or call option, the same strike price, must be entered in good faith for the purpose of executing bona fide transactions that result in a change of ownership. Additionally, no person shall accept, execute or accommodate the execution of orders which are prohibited by this rule with knowledge of their character.

FINDINGS:

Pursuant to an offer of settlement in which Robert Zygmunt neither admitted nor denied the rule violations upon which the penalty is based, on July 28 2011, a Panel of the CME Business Conduct Committee found that on April 30, 2009, Zygmunt accepted buy and sell orders in the same product and expiration month for various CME Group futures contracts that were ultimately executed on the CME Globex Electronic trading platform for accounts with the same beneficial owner. The Panel found that in so doing, Zygmunt violated CME Rule
534.

PENALTY:

In accordance with the settlement offer, the Panel suspended Zygmunt's direct access to any electronic trading or clearing platform owned or controlled by CME Group for twenty business days. The suspension will run from August 1,
2011, through August 26, 2011, inclusive.

EFFECTIVE DATE:

August 1, 2011