NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 11-8030-BC

CME MEMBER:

THOMAS A. HALPIN

CME RULE VIOLATIONS:

432. General Offenses

It shall be an offense:

B.1. to engage in fraud or bad faith

B.2. to engage in conduct or proceedings inconsistent with just and equitable
principles of trade;

H. to…offer to purchase or sell Exchange futures or options contracts, or any underlying commodities or securities, for the purpose of upsetting the equilibrium of the market or creating a condition in which prices do not or will not reflect fair market values;

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange:

T. to engage in dishonorable or uncommercial conduct;

FINDINGS:

Pursuant to an offer of settlement Thomas A. Halpin (“Halpin”) presented at a hearing on June 6, 2012, in which Halpin neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the CME Business Conduct Committee (“BCC”) found that on 17 days between December 1, 2010 and September 13, 2011, Halpin entered bids, offers and modifications during the pre-open period in Lean Hogs and Live Cattle at prices through the existing bid/offer, which were often cancelled prior to the time the market reopened for trading. The Panel also found that the entry, modification and cancellation of these orders caused excessive fluctuations in the publicly displayed Globex Indicative Opening Price.

The Panel found that as a result, Halpin violated Rules 432.B.1; B.2: H; Q and T.

PENALTY:

In accordance with the settlement offer, the Panel ordered Halpin to pay a fine to the Exchange in the amount of $20,000.

EFFECTIVE DATE:

June 8, 2012