George Dennis, a non-member of the New York Mercantile Exchange, was prohibited from trading on any CME Group market for five years for not cooperating with a NYMEX investigation. Apparently, in connection with an investigation into an unspecified matter, Mr. Dennis failed to show up for an interview with NYMEX’s Market Regulation staff. For that, he was charged with a violation of a CME Group rule that requires even non-members to cooperate fully with exchange investigations, including participating in interviews. (Click here to access CME Group Rule 432L.1) Mr. Dennis subsequently failed to show up at an exchange hearing related to charges against him or his penalty hearing.

Compliance Weeds: By trading on CME Group, even a non-member submits to the jurisdiction of the exchange “and agrees to be bound by and comply with [all its rules], including, but not limited to, rules requiring cooperation and participation in investigatory and disciplinary procedures. (Click here to access CME Group Rule 418.) Other futures exchanges have similar rules. (Click here to access, e.g., ICE Futures U.S. Rule 4.00.)