NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

BRADLEY CHARLES YAM

CME RULE VIOLATIONS:

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 Bradley Charles Yam (“Bradley Yam”) 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 Bradley Yam pursuant to Rules 400 and 402 as the conduct occurred while Bradley Yam was an employee of a CME member firm. The Panel also found that on April 20, 2012, Bradley Yam received a customer order to sell a put spread in Eurodollar options on futures. After a fill was communicated to the customer, the same customer placed a second order. Upon receiving the second order, Bradley Yam communicated a fill to the customer on the order before execution occurred in the pit. The Panel concluded that Bradley Yam thereby violated CME Rule 540.

PENALTY:

In accordance with the settlement offer, the Panel ordered Bradley Yam to pay a fine of $17,000 and serve a ten 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 8, 2015, inclusive.

EFFECTIVE DATE:

May 26, 2015