NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Michel Simonian

EXCHANGE RULE: Rule 432. – General Offenses

It shall be an offense:

B.2. to engage in conduct or proceedings inconsistent with just and
equitable principles of trade;

Q. to commit an act 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;

FINDINGS:

Pursuant to an offer of settlement that Michel Simonian (“Simonian”) presented at a hearing on March 18, 2015, in which Simonian neither admitted nor denied the findings or the rule violations upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“Panel”) found that Simonian is subject to the jurisdiction of the Exchange pursuant to Rules 400 and 402 as the conduct occurred while Simonian was employed by a member of the Exchange.

The Panel also found that on several trade dates between March 2013 and January 2014, Simonian engaged in a pattern of activity in which he entered large manual orders in the Silver futures contracts without the intent to trade. Specifically, he entered these large orders to observe the market’s reaction and to encourage market participants to trade opposite his smaller iceberg orders that were resting on the opposite side of the book. After receiving a fill on his iceberg orders, Simonian would then cancel the resting large orders he had entered on the opposite side of the order book, within approximately one second.

The Panel found that as a result of the foregoing, Simonian violated COMEX Rules 432.B.2., 432.Q.

PENALTY:

In accordance with the settlement offer, the Panel ordered Simonian to pay a fine to the Exchange in the amount of $35,000 and suspended Simonian’s access to any CME Group trading floor, and direct or indirect access to any CME Group electronic trading or clearing platform for 15 business days, beginning on the effective date below. The suspension will run from March 20, 2015 through April 10, 2015.