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U.S. Futures Exchanges Disciplinary Actions Alert: January 2018

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month.  The report has a particular focus on notices potentially relevant to energy commodities and is not intended to be a comprehensive review of each and every notice issued.  Instead, the report is intended to provide market participants, and compliance personnel in particular, with illustrative examples of rule violations and to bring to light enforcement trends across the exchanges.  The disciplinary notices cited in this report can be found at www.cmegroup.com and www.theice.com/futures-us/notices.


CBOT 16-0547-BC
Disruptive Trading
Violation of Rule 575.A – Disruptive Practices Prohibited

Pursuant to a settlement offer, a Business Conduct Committee Panel (“BCC Panel”) found that on multiple occasions between December 1, 2015 and August 15, 2016, a member entered bids and offers on Globex during the pre-open period of various CBOT grains and oilseeds futures contracts.  These bids and offers were not entered for the purpose of executing bona fide transactions.  The entry and cancellation of these orders caused fluctuations in the publicly displayed Indicative Opening Price.  $25,000 fine and 30-day suspension.


NODAL 0314205
Block Trades

On four occasions from December 2016 through February 2017, an entity reported block trades to the Exchange later than 15 minutes after execution, in violation of Exchange Rule 4.6.2(f), but these violations did not result in financial harm to customers.  $5,500 fine.

© 2022 Bracewell LLPNational Law Review, Volume VIII, Number 37

About this Author

David Perlman, Energy Practice, Partner, Lawyer, Bracewell law firm

David Perlman is a partner in the energy practice in Bracewell's Washington, D.C. office. He represents and counsels clients before regulatory bodies such as the Federal Energy Regulatory Commission (FERC), Commodity Futures Trading Commission and state public utility commissions in regulatory and compliance matters, in the conduct of compliance programs and training, and in energy-related transactions and financings.

Mr. Perlman represents a variety of clients, including utilities, commodities merchants, marketers, industrial customers,...

Robert E. Pease, Energy, Attorney, Bracewell law firm
Senior Counsel

Bob Pease represents clients involved in the energy sector in CFTC and FERC regulatory, compliance and enforcement matters involving power, gas, and crude oil, as well as Dodd Frank implementation. Bob has more than 25 years of senior-level experience at CFTC and FERC handling energy-related policy, compliance and enforcement matters, most recently as Counsel to the Director in the Division of Enforcement with the CFTC. Before his time with the CFTC, Bob spent more than 20 years at FERC most recently as Director of Investigations. Bob was involved in some of the...

Ryan M. Eletto, Bracewell, environmental strategy lawyer, energy regulatory matters attorney

Ryan Eletto focuses his practice on energy regulation, environmental strategy, regulatory matters and public policy issues. He advises energy companies and other clients in litigation, investigation, enforcement and compliance matters involving administrative agencies, including the Federal Energy Regulatory Commission and the Commodity Futures Trading Commission. 

Prior to joining Bracewell, Ryan served as a law clerk to the Honorable Bruce E. Kasold of the U.S. Court of Appeals for Veterans Claims in Washington, D.C.