David Rothner and Nancy J. Rothner - Page 6

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          which the proceedings against petitioner were based arose out of            
          petitioner's business as a floor broker.  Petitioner had                    
          previously paid a $1,000 fine to the CME for violating its rule             
          limiting the amount of trading among members of the same                    
          brokerage association.  Sanctions imposed by the CME during 1987            
          and 1988 for violations of its rules governing brokerage                    
          associations tended to consist of warning letters and fines                 
          ranging from $1,000 to $10,000.                                             
               Petitioner, Mr. Lowrance, Mr. Maloney, and Mr. Elliott made            
          offers to settle the charges against each of them without                   
          admitting or denying violations of the CME's rules.  Based on the           
          offers, the CME's Business Conduct Committee concluded that                 
          petitioner, Mr. Lowrance, and Mr. Maloney each pre-arranged                 
          Eurodollar futures trades with Mr. Elliott for the purpose of               
          evading the CME's limits on execution of customer orders with               
          other members of the same brokerage association.  In so doing,              
          the committee concluded that each of those individuals had                  
          committed an act that was substantially detrimental to the                  
          interest or welfare of the CME, a major offense pursuant to the             
          CME's rules, and had engaged in prohibited pre-arranged trading,            
          a minor offense pursuant to those rules.  The committee                     
          accordingly imposed the following fines and suspensions of                  
          exchange membership privileges:                                             








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