NOTICE OF DISCIPLINARY ACTION

MEMBER:

Andrew D. Rudich

CME RULE VIOLATIONS:

CME Rule 432. General Offenses

It shall be an offense:

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

CME Rule 532. Disclosing Orders Prohibited (in part)

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.

FINDINGS:

Pursuant to an offer of settlement in which Andrew D. Rudich (“Rudich”) neither admitted nor denied the rule violations upon which the penalty is based, on March 9, 2016, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that Rudich was subject to the BCC’s jurisdiction pursuant to Rules 400 and 402 as the conduct occurred while Rudich was a CME member. The Panel further found that between March 1, 2012, and July 25, 2012, Rudich traded based on non-public order information in the Lean Hogs futures market. Specifically, the Panel determined that on numerous occasions, prior to the beginning of the closing range, Rudich established a position for his personal account on the CME Globex platform based on his knowledge of the customer Market on Close orders in his possession prior to the beginning of the closing range. Rudich then offset those positions in the pit during the closing range. The Panel concluded that Rudich thereby violated CME Rules 432.B.2. and 532.

PENALTY:

In accordance with the settlement offer, the Panel ordered Rudich to disgorge profits in the amount of $114,680, pay a fine in the amount of $25,000, and serve a one year suspension from access to any CME Group Inc. trading floor and direct and indirect access to any electronic trading and clearing platform owned or operated by CME Group Inc., including CME Globex. The suspension shall run from March 11, 2016 through March 11, 2017, inclusive.

EFFECTIVE DATE:

March 11, 2016