NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

William Michael Fenton

CME RULE VIOLATION:

538.H. Documentation

Parties to any EFRP transaction must maintain all documents relevant to the Exchange contract and the cash, OTC swap, OTC option, or other OTC derivative, including all documents customarily generated in accordance with relevant market practices and any documents reflecting payment and transfer of title. Any such documents must be provided to the Exchange upon request, and it shall be the responsibility of the carrying clearing member firm to provide such requested documentation on a timely basis.

FINDINGS:

Pursuant to an offer of settlement in which William Michael Fenton (“Fenton”) neither admitted nor denied the rule violation upon which the penalty is based, on July 16, 2015, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel or BCC”) found that it has jurisdiction over Fenton pursuant to Rules 402 and 418, and that on February 7, 2014, Fenton entered into a transitory EFRP transaction in a CME foreign exchange (“FX”) product that did not contain documentation of the corresponding cash position and, thus, was not a bona fide EFRP transaction.

The Panel concluded that Fenton thereby violated CME Rule 538.H.

PENALTY:

In accordance with the settlement offer, the Panel ordered Fenton to pay a fine of $7,500.

EFFECTIVE DATE:

July 20, 2015