NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

BRUNO CORDEIRO

EXCHANGE RULES:

Rule 432. General Offenses (in part)

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 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 that Bruno Cordeiro (“Cordeiro”) presented at a hearing on September 30, 2015, in which Cordeiro neither admitted nor denied the factual allegations or rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found it had jurisdiction over Cordeiro pursuant to Exchange Rules 402 and 418 and that on multiple trade dates during the time period from January 2013 through February 2014, Cordeiro, while employed as a trader for a non-member firm, engaged in a pattern of activity in which he entered large orders in Palladium futures contracts without the intent to trade. Specifically, Cordeiro entered these large orders to encourage market participants to trade opposite his smaller orders that were resting on the opposite side of the book. After receiving a fill on his smaller orders, Cordeiro would then cancel the resting large orders he had entered on the opposite side of the order book.

The Panel concluded that Cordeiro violated Exchange Rules 432.B.2., 432.Q., and 432.T.

PENALTY:

In accordance with the settlement offer, the Panel ordered Cordeiro to (1) pay a fine to the Exchange in the amount of $50,000; and (2) serve a 10 business day suspension from (a) applying for membership at any CME Group exchange; (b) direct or indirect access to all electronic trading and clearing platforms owned or controlled by the CME Group Inc., including CME Globex; and (c) access to any trading floor owned or controlled by any CME Group, Inc. exchange. The suspension shall run from October 2, 2015 through and including October 15, 2015.