NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Aaron Wilkey

CME RULE VIOLATIONS:

Rule 432. General Offenses

It shall be an offense:

G. To prearrange the execution of transactions in Exchange products for the purpose of transferring equity between accounts.

FINDINGS:

On March 24, 2015, a Panel of the Chicago Mercantile Exchange (“CME”) Probable Cause Committee (“PCC”) charged non-member Aaron Wilkey (“Wilkey”) with violating CME Rule 432.G. based on allegations that on nine days between June 1, 2011, and August 31, 2011, Wilkey executed numerous noncompetitive round-turn transactions over the CME Globex electronic trading platform for the purpose of transferring equity between two accounts. Specifically, Wilkey prearranged 42 trades constituting 20 round turn transactions in Feeder Cattle and Live Cattle futures contracts for the purpose of transferring $6,285.00 from his mother’s account to his wife’s account. Wilkey entered identical limit prices for opposing orders on each occasion, entered equal order quantities in 40 of the 42 transactions, and entered the opposing buy and sell orders within a short period of time. Further, Wilkey’s wife’s account profited in every round turn transaction while his mother’s account lost.

On August 10, 2015, and in accordance with Rule 407.C., a Hearing Panel Chair of the CME Business Conduct Committee (“BCC”) found that Wilkey had failed to answer the charge issued against him by the CME PCC. The Hearing Panel Chair accordingly ruled that in failing to answer the charge issued Wilkey was deemed to have admitted the charge, and through this admission Wilkey had waived his right to a hearing on the merits of the charge.

On November 2, 2015, a Panel of the CME BCC found that Wilkey committed the violation contained in the admitted charge, and subsequently held a penalty hearing.

PENALTY:

Based on the record and the Panel’s findings and conclusions, the Panel ordered that Wilkey be barred permanently from (1) applying for membership at any CME Group exchange; (2) direct or indirect access and use of any trading floor, electronic trading platform or clearing platform owned or operated by any CME Group exchange; and (3) affiliation with, employment by, or association with a Member (as this term is defined in Rule 400) or affiliate of a Member of any CME Group exchange.

EFFECTIVE DATE:

March 1, 2016