NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

RYAN ALEXANDER ARENSON

CME RULE VIOLATIONS:

Rule 548. Priority of Execution (in part)

In pit trading, non-discretionary customer orders shall be executed in accordance with their price and time priority. A member shall not execute a discretionary order, including, without limitation, an order allowing the member discretion as to time and price, while in possession of an executable customer order. No person shall allocate executions in any manner other than an equitable manner.

Rule 540. Responsibility of Customer Orders (in part)

A Member (as defined in Rule 400) is prohibited from directly or indirectly guaranteeing the execution of an order or any of its terms such as quantity or price. A Member may only report an execution that has occurred as a result of open outcry, has been effected through the Globex platform, or has been executed as a permissible privately negotiated transaction. This rule shall not be construed to prevent a Member from assuming or sharing in the losses resulting from an error or the mishandling of an order.

FINDINGS:

Pursuant to an offer of settlement in which Ryan Alexander Arenson (“Arenson”) neither admitted nor denied the rule violations upon which the penalty is based, on May 21, 2015, a Panel of the CME Business Conduct Committee (“Panel”) found that it had jurisdiction over Arenson pursuant to Exchange Rules 400 and 402 as the conduct occurred while Arenson was an employee of a CME member firm. The Panel also found that on April 16, 2012, Arenson received a customer limit order to buy Eurodollar options on futures, and partially filled that order. Arenson then contacted a second customer and guaranteed an execution on that customer’s buy order in the same product and at the same price as the first customer’s order before relaying the order to the Eurodollar options on futures pit. Although a balance on the initial order remained, Arenson’s second customer received a fill on the full quantity of this order despite the initial customer order’s priority. The Panel concluded that Arenson thereby violated CME Rules 548 and 540.

PENALTY:

In accordance with the settlement offer, the Panel ordered Arenson to pay a fine of $20,000 and serve a seven business day suspension of access to any CME Group Inc. trading floor and of direct access to all electronic trading and clearing platforms owned or controlled by CME Group, Inc., including CME Globex. The suspension shall run from May 26, 2015, through June 3, 2015, inclusive.

EFFECTIVE DATE:

May 26, 2015