NOTICE OF DISCIPLINARY ACTION

MEMBER:

ROBERT LEEDS

EXCHANGE RULES: 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 dishonorable or uncommercial conduct:

FINDINGS:

Pursuant to an offer of settlement Robert Leeds (“Leeds”) presented at a hearing on January 15, 2015, in which Leeds neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC Panel”) found that Leeds was subject to the jurisdiction of the Exchange pursuant to Exchange Rules 400 and 402 as the conduct occurred while Leeds was a NYMEX member. The Panel also found that on one or more occasions between January 2013 and April 2013, Leeds entered orders in Natural Gas futures contracts on the CME Globex electronic trading platform during the pre-opening session that were not for the purpose of executing bona fide transactions. The Panel further found that the entry and subsequent cancellation of these orders caused fluctuations in the publicly displayed Indicative Opening Price.

The Panel found that as a result of the foregoing, Leeds violated Rule 432.Q. and 432.T.

PENALTY:

In accordance with the settlement offer, the BCC Panel ordered Leeds to pay a fine of $20,000. The Panel also ordered Leeds to serve a 15 business day suspension from membership privileges on any CME Group Inc. Exchange; access to all CME Group Inc. trading floors; and direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc., including CME Globex. The suspension shall run from February 10, 2015, through and including March 3, 2015.