NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

JONATHAN BRIMS

CBOT RULE VIOLATIONS:

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;

FINDINGS:

Pursuant to an offer of settlement in which Jonathan Brims (“Brims”) neither admitted nor denied the rule violations upon which the penalty is based, on January 20, 2015, a Panel of the CBOT Business Conduct Committee (“BCC” or “Panel”) found that it had jurisdiction over Brims pursuant to CBOT Rules 400 and 402 as the conduct occurred while Brims was an employee of a CBOT member firm. The Panel also found that during the time period from September 2011 through December 2012, Brims, on multiple occasions, entered large orders in the 5-Year Note, 10-Year Note, Bond, and Ultra Bond futures contract markets without the intent to trade. The Panel specifically found that Brims placed a small order to sell (buy) in the futures contract market on the CME Globex electronic trading platform (“Globex”). Brims subsequently entered multiple large-lot buy (sell) orders at or near the best bid (offer) on Globex to create the appearance of an imbalance in buy/sell pressure. Once the small order began trading, Brims canceled the large orders. The Panel further found that Brims entered the large orders for the purpose of inducing other market participants to trade against the small orders resting on the other side of the order book. The Panel concluded that Brims thereby violated CBOT Rules 432.B.2. and 432.Q.

PENALTY:

In accordance with the settlement offer, the Panel ordered Brims to pay a fine to the Exchange in the amount of $50,000 and serve a ten business day suspension of access to any CME Group Inc. trading floor and of 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 January 22, 2015, through February 4, 2015, inclusive.

EFFECTIVE DATE:

January 22, 2015