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      • CME 12-9067-BC-7
      • Effective Date
      • 26 May 2015



      Rule 532. Disclosing Orders Prohibited (in part)

      …[N]o person shall disclose another person’s order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. 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.

      Rule 539. Prearranged, Pre-Negotiated and Noncompetitive Trades Prohibited (in part)

      A. General Prohibition

      No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction…


      Pursuant to an offer of settlement in which Mathew Laurence Woodley (“Woodley”) 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 Woodley pursuant to Exchange Rules 400 and 402 as the conduct occurred while Woodley was an employee of a CME member firm. The Panel also found that on July 2, 2013, Woodley, after having received a customer’s buy order for execution in the Eurodollar options on futures pit, disclosed to the buy-order customer the existence of sell orders and the size of the offered quantities received from other customers also for execution in the pit. Woodley disclosed the customers’ nonpublic sell-order information to the buy-order customer prior to presenting the sell orders to the pit. To further ensure that the opposing customer orders traded opposite each other, Woodley simultaneously placed both the buy and sell orders into the pit for execution, and, one minute later, adjusted the price of the buy order to match the price of the sell order. The Panel concluded that Woodley thereby violated CME Rules 532 and 539.A.


      In accordance with the settlement offer, the Panel ordered Woodley 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 June 8, 2015, through June 16, 2015, inclusive.


      May 26, 2015