NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Brian M. Bunn

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…

FINDINGS:

Pursuant to an offer of settlement in which Brian M. Bunn (“Bunn”) neither admitted nor denied the rule violation upon which the penalty is based, on November 4, 2015, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that Bunn was subject to the BCC’s jurisdiction pursuant to Rules 400 and 402 as the conduct occurred while Bunn was employed by a CME member firm. The Panel further found that Bunn, a clerk, directed the execution of customer orders that were not openly bid to the pit. Specifically, on June 14, 2013, and October 2, 2013, Bunn received separate buy and sell orders from the same customer in the Eurodollar options on futures pit and subsequently directed specific brokers to execute the orders with the understanding that a portion of the orders would cross. As a result, the Panel concluded that Bunn thereby violated CME Rule 539.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Bunn to pay a fine in the amount of $12,500 and serve a 5 business day 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 November 9, 2015 through November 13, 2015, inclusive.

EFFECTIVE DATE:

November 6, 2015