The Chicago Board of Trade and the Chicago Mercantile Exchange each brought and settled disciplinary actions against Fredrik Nielsen, a nonmember, claiming that between February 2013 and February 2014 he engaged in a “pattern of activity” where he would layer orders on one side of a market “without the intent to trade.” He did this to allegedly induce market participants to trade opposite smaller orders he had resting on the other side of the market. Once those smaller orders began being executed, Mr. Nielsen purportedly cancelled his remaining layered orders. Mr. Nielsen agreed to resolve these actions by paying a combined penalty of US $65,000 and being suspend from access to all CME Group markets for three weeks. Separately, both OZ Management LP and Yannix Management LP, nonmembers, agreed to resolve disciplinary actions by CME Group exchanges for allegedly engaging in exchange for related position transactions that were prohibited transitory EFRPs. CME Group claimed, in both matters, that the related position transactions “were not independent transactions exposed to market risk.” Both firms settled their unrelated disciplinary action through payment of a US $15,000 fine. Finally, Ronald Sippel, a member, resolved a disciplinary action brought by CME by agreeing to pay a fine of US $55,000 and having his access to CME Group exchanges suspended for 10 business days. Mr. Sippel was charged with executing multiple trades for accounts opposite each other, where he controlled the accounts on both sides. His intent, said the CME Group, was to transfer positions from one account to another.