NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Cody Easterday

CME RULE VIOLATIONS:

432. General Offenses

It shall be an offense:

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange;

T. to engage in… uncommercial conduct;

FINDINGS:

Pursuant to an offer of settlement in which Cody Easterday (“Easterday”) neither admitted nor denied the rule violations upon which the penalty is based, on October 20, 2015, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that in 12 instances between January 27, 2013, and February 24, 2014, Easterday entered buy orders in both Live Cattle and Feeder Cattle futures contracts during the pre-opening session at prices higher than the prevailing bid, which were not made in good faith for the purpose of executing bona fide transactions. The entry and cancelation of these orders caused excessive fluctuations in the publicly displayed Indicative Opening Price (“IOP”). The Panel concluded that Easterday thereby violated Rules 432.Q. and T.

PENALTY:

In accordance with the settlement offer, the Panel ordered Easterday to pay a fine to the Exchange in the amount of $20,000 and have his access to all CME Group trading floors and direct access to all electronic trading and clearing platforms owned or controlled by CME Group suspended for 15 business days.

EFFECTIVE DATE:

October 22, 2015