NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 09-06429-BC

NON-MEMBER CLERK:

SEAN MOORE

CME RULE VIOLATIONS:

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.

FINDINGS:

Pursuant to an offer of settlement in which Sean Moore (“Moore”) 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 May 6, 2010, Moore failed to inquire as to the beneficial ownership of accounts for which he had received simultaneous buy and sell instructions. The Panel found that in so doing, Moore violated CME Rule 534.

PENALTY:

In accordance with the offer of settlement, the Panel fined Moore $5,000 and suspended his access to the trading floor and his direct access to any CME Group electronic trading or clearing platform for 5 business days, beginning on the effective date below.

EFFECTIVE DATE:

April 2, 2012