Andrew Rudich, a member of the Chicago Mercantile Exchange, agreed to settle charges brought by the CME that, on numerous occasions between March 1, 2012, and July 25, 2012, he personally traded based on non-public information regarding a customer’s intended transactions. During this time, claimed CME, Mr. Rudich personally traded in Lean Hogs futures contracts prior to the beginning of the closing range based on his knowledge of a customer’s market on close orders. According to CME, Mr. Rudich then closed his positions during the closing range. Mr. Rudich agreed to resolve CME’s charges by disgorging profits of US $114,000, paying a fine of US $25,000 and not trading any CME Group product for one year. Separately, Penson Futures agreed to pay a fine of US $100,000 for impermissibly netting down certain long and short futures positions on the Chicago Board of Trade on 35 occasions between July and September 2010. According to the CBOT, during this time, Penson netted down long and short futures positions during the first two business days prior to the delivery month and during the delivery month for various expiring agricultural futures contracts. These close-outs exceeded one percent of the open interest of the relevant futures contract, in violation of relevant CBOT rule (click here to access the relevant legacy CBOT Rule 854B within the notice of Penson's disciplinary action). Penson reported these close-outs were the result of an “error.”