NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Rohit Chopra

CME RULE VIOLATIONS:

Rule 432 General Offenses

It shall be an offense:

B. 1. to engage, or attempt to engage, in fraud or bad faith;

C. to engage in dishonest conduct;

T. to engage in dishonorable or uncommercial conduct;

U. except where a power of attorney or similar document has been executed pursuant to Rule 956, for any party to accept or transmit a customer order which has not been specifically authorized.

FINDINGS:

Pursuant to an offer of settlement in which Rohit Chopra neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on December 21, 2022, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that Chopra operated a futures trading program that allocated trades to its participants at the end of each trading day according to individual allocation schemes. From August 10, 2020, through August 13, 2020, Chopra placed uncharacteristically large and unprofitable trades on behalf of his customers. By the close of trading on August 10, 2020, most of the accounts Chopra traded were debit. On August 11, 2020, following additional losses, several introducing brokers at the behest of their clients directed Chopra to suspend trading their clients’ accounts or set their accounts to liquidation-only status. Chopra assured the introducing brokers that he would only place orders to liquidate existing positions. However, Chopra entered unauthorized trades in the September 2020 E-Mini S&P, E-Mini Nasdaq, and E-Mini Russell futures markets for the accounts, which resulted in additional losses for those customers. As a result, by August 12, 2020, all but one customer ceased participating in Chopra’s futures trading program. Chopra continued to place large unprofitable trades on behalf of the remaining customer until his executing broker liquidated the customer’s large positions and disabled Chopra's access to the broker’s trading platform on August 13, 2020.

The Panel concluded that Chopra thereby violated CME Rules 432.B.1., C., T., and U.

PENALTY:

In accordance with the settlement offer, the Panel ordered Chopra to: pay a fine in the amount of $300,000 in connection with this case and companion cases NYMEX 20-1380-BC and COMEX 20-1380-BC ($200,000 of which is allocated to CME); pay restitution of $287,492.69 to the account owners disadvantaged as a result of the activity; be permanently suspended from trading, placing, entering, accepting, and soliciting orders in all products on behalf of customers; and be suspended from access to any trading floor owned or controlled by CME Group and from direct and indirect access to any designated contract market, derivatives clearing organization or swap execution facility owned or controlled by CME Group for five years, beginning on the effective date and continuing for five years from the date that the ordered fine and restitution is paid.