CHRISTOPHER J. CLARK (CCL)
CME RULE VIOLATIONS:
532. Disclosing Orders Prohibited
No person shall disclose another person's order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. An order for pit execution is not considered public until it has been bid or offered by open outcry. No person shall take action or direct another to take action based on non-public order information, however acquired. The mere statement of opinions or indications of the price at which a market may open or resume trading does not constitute a violation of this rule.
534. WASH TRADES PROHIBITED
No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.
Pursuant to an offer of settlement in which Christopher J. Clark (“Clark”) neither admitted nor denied the rule violations upon which the penalty is based, on March 29, 2012, a Panel of the CME Business Conduct Committee found that on one or more occasions in February 2009, Clark disclosed the terms of his customer’s orders to another market participant prior to the exposure of the order to the marketplace. Additionally, on May 6, 2010, Clark failed to inquire as to the beneficial ownership of the accounts for which he placed simultaneous buy and sell orders. The Panel found that in so doing, Clark violated CME Rules
532 and 534.
In accordance with the offer of settlement, the Panel fined Clark $15,000 and suspended his membership privileges, access to the trading floor, and his direct access to any CME Group electronic trading or clearing platform for 10 business days, beginning on the effective date below.
April 2, 2012