NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Benjamin Roth

CME RULE VIOLATIONS:

Rule 575 (“Disruptive Practices Prohibited”) (in part)

A. No person shall enter or cause to be entered an order with the intent, at the time of order entry, to cancel the order before execution or to modify the order to avoid execution.

FINDINGS:

Pursuant to an offer of settlement in which Benjamin Roth neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on June 26, 2024, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that on several occasions between January 3, 2023, and February 2, 2023, Roth entered orders in the March 2023 E-Mini S&P 500 futures and the March 2023 Australian Dollar futures markets with the intent, at the time of order entry, to cancel the orders before execution or to modify the orders to avoid execution. Specifically, Roth entered a larger order on one side of the market and then canceled that order after his smaller resting order on the opposite side of the book was executed. The resulting benefit to Roth was $20,825.

The Panel concluded that as a result of the foregoing, Roth violated CME Rule 575.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Roth to pay a fine of $20,000, pay disgorgement in the amount of $20,825, and serve a 40-business day suspension 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, beginning on the effective date below and continuing through and including August 23, 2024.

EFFECTIVE DATE:

June 28, 2024