NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Rahul Seksaria

CME RULE VIOLATIONS:

Rule 432 (“General Offenses”) (in part):

It shall be an offense:
G. to prearrange the execution of transactions in Exchange products for the purpose of transferring equity between accounts;

Q. It shall be an offense 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.

539. Prearranged, Pre-Negotiated and Noncompetitive Trades Prohibited (in part)
A. No person shall prearrange or pre-negotiate any purchase or sale or
noncompetitively execute any transaction…

FINDINGS:

On July 9, 2014, a Panel of the Chicago Mercantile Exchange (“CME”) Probable Cause Committee (“PCC”) charged Rahul Seksaria (“Seksaria”) with violating CME Rules 432.G., 432.Q. and 539.A., based on allegations that on April 5, 2012, Seksaria orchestrated and prearranged trades in the June 2015 Eurodollar futures contract opposite one of his employer’s client suspense account, which resulted in the transfer of $2,675 from the suspense account to his personal trading account.

On November 13, 2014, a Hearing Panel Chair of the CME Business Conduct Committee (“BCC”) entered an order finding that Seksaria failed to answer the charges issued against him. In failing to answer the charges, the Hearing Panel Chair further ordered that Seksaria was deemed to have admitted the charges issued, and that Seksaria had waived his right to a hearing on the merits of the charges.

At a hearing on December 17, 2014, Seksaria voluntarily submitted to the jurisdiction of the BCC for purposes of settling the matter and submitted an offer of settlement. The Panel of the BCC (“Panel”) found that Seksaria committed the violations alleged in the notice of charges.

PENALTY:

In accordance with the settlement offer, and the Panel’s findings and conclusions, the Panel ordered Seksaria to pay a fine of $65,000, $2,675 in restitution, and barred Seksaria from accessing any CME Group Inc. trading floor, and direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. for three months, beginning on the effective date below and continuing through and including March 19, 2015.

EFFECTIVE DATE:

December 19, 2014