NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 13-9427-BC

MEMBER:

Lindsey Kenny

CME RULE VIOLATION:

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

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

540. Responsibility for Customer Orders (in part)

A Member is prohibited from directly or indirectly guaranteeing the execution of an order or any of its terms such as the 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.

FINDINGS:

Pursuant to an offer of settlement in which Lindsey Kenny (“Kenny”) neither admitted nor denied the rule violations upon which the penalty is based, on November 18, 2014, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that it had jurisdiction over Kenny pursuant to Rules 400 and 402 as the conduct occurred while Kenny was a CME member. The Panel further found that on February 22, 2013, and October 18, 2013, Kenny guaranteed the fill of an order prior to its execution in the Eurodollar options on futures pit. In addition, the Panel found that Kenny directed the execution of customer orders that were not openly bid to the pit. Specifically, on February 22, 2013, Kenny received separate buy and sell orders from the same customer and subsequently directed specific brokers to execute the order with the understanding that a portion of the orders would cross. As a result, the Panel concluded that Kenny thereby violated CME Rules 539.A, and 540.

PENALTY:

In accordance with the settlement offer, the Panel ordered Kenny to pay a fine of $20,000. The Panel also suspended Kenny from accessing any CME Group Inc. trading floor, and direct access to all electronic trading and clearing platforms owned or controlled by CME Group for 20 business days, beginning on November 20, 2014, and continuing through and including December 18, 2014.

EFFECTIVE DATE:

November 20, 2014