BEFORE THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED

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1 BEFORE THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED In the Matter of: Centurion Securities, LLC 2 Rector Street 16 th Floor New York, New York and Gary Anderson 2 Rector Street File No th Floor New York, New York and Victor DiMaggio III DiMaggio and Robinson, Ltd. 216 W. Jackson Blvd. Suite 925 Chicago, IL Subjects DECISION ACCEPTING LETTER OF CONSENT This proceeding was instituted by the Business Conduct Committee (the Committee of the Chicago Board Options Exchange, Incorporated (the Exchange as a result of an investigation by the staff of the Exchange. In order to resolve this matter, the subjects, Centurion Securities, LLC, Gary Anderson and Victor DiMaggio III, have submitted a Letter of Consent. Such Letter of Consent was submitted solely for the purposes of this proceeding without admitting or denying that a violation of Exchange Rules has been committed. With due regard to the stipulated facts and findings and the proposed sanction contained therein, the Committee believes it is appropriate to accept the Letter of Consent for File No which is attached to and made a part of this Decision. SO ORDERED FOR THE COMMITTEE Dated: March 23, 2007 By: /s/ Bruce Andrews Bruce Andrews Chairman Business Conduct Committee

2 BEFORE THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED In the Matter of: Centurion Securities, LLC 2 Rector Street 16 th Floor New York, New York File No Gary Anderson 2 Rector Street 16 th Floor New York, New York Victor DiMaggio III DiMaggio and Robinson, Ltd. 216 W. Jackson Blvd. Suite 925 Chicago, IL Respondents LETTER OF CONSENT In order to resolve this proceeding pursuant to Chicago Board Options Exchange, Incorporated (the Exchange or CBOE Rule 17.3, Expedited Proceeding, the Subjects, Centurion Securities, LLC ( Centurion, Gary Anderson ( Anderson and Victor DiMaggio III, ( DiMaggio, hereby submit this Letter of Consent in the above captioned matter. Only for purposes of this proceeding and without admitting or denying that a violation of Exchange Rules has been committed, Centurion, Anderson and DiMaggio consent to the Stipulation of Facts and Findings and Sanction set forth below. Stipulation of Facts and Findings 1. During all relevant periods herein, the Subject, Centurion was a member of the Exchange registered with the Exchange as a Market-Maker organization. In addition, Centurion conducted a proprietary trading business. 2. During all relevant periods herein, the Subject, Anderson was an Associated Person of Centurion and Compliance Officer of Centurion with responsibilities that include monitoring Centurion s books and records and Regulation SHO markings and locates. 3. During all relevant periods herein, the Subject, DiMaggio was an Associated Person of Centurion and Financial and Operational Principal ( FINOP of Centurion with responsibilities that include monitoring Centurion s net capital computations.

3 4. During all relevant periods in which the activity noted below occurred, Centurion was acting as a registered broker/dealer. 5. During all relevant periods herein, Exchange Rules Adherence to Law; 3.7 Certain Documents Required of Members, Applicants and Associated Persons; 15.1 Maintenance, Retention and Furnishing of Books, Records and Other Information; Section 15(c of the Securities Exchange Act of 1934, as amended (the Act and Rule 15c3-1 - Net Capital thereunder; Section 17(a of the Act and Rules 17a-3 Records to Be Made by Certain Exchange Members, Brokers and Dealers; 17a-4 Records to Be Preserved by Certain Members, Brokers and Dealer and 17a-5 Reports to Be Made by Certain Brokers and Dealers thereunder; Securities and Exchange Commission ( SEC Regulation SHO Short Sales and Rules 200 Definitions and Marking Requirements for Short Sales and 203(b Locate and Requirements for Short Sales thereunder, were in full force and effect. 6. During all relevant periods herein, pursuant to SEC Regulation SHO, broker dealers, prior to effecting a short sale in equity security, are required to locate securities available for borrowing and the locate must be made and documented prior to effecting a short sale. 7. In or about March 2006, the Exchange conducted a Routine Financial and Operational Examination ( Examination of Centurion that included, but was not limited to, a review of the policies, procedures, and practices of Centurion s books and records, Regulation SHO compliance program, and net capital reports. 8. In or about March 2006, Centurion improperly marked its stock activity in that Centurion s stock activity recorded on its Trade Blotter did not accurately reflect the stock activity recorded in Centurion s Net Position Records and Haircut Report. 9. In or about March 2006, Centurion improperly marked 105 of 319 trades, of which 98 of 158 short sale stock trades, or 62%, were improperly marked as sell long instead of sell short when Centurion was not long the position. 10. In or about March 2006, Centurion failed to perform a stock locate for any of the short sale stock transactions described above in Paragraph In or about March 2006, Centurion failed to update its form BD on Web CRD to accurately reflect Centurion s current members and current ownership percentages. 12. In or about March 2006, Centurion overstated its net capital by $5,243,739 or approximately 844%. 13. In or about March 2006, Anderson failed to monitor the accuracy of Centurions books and records when (i Centurion s trades were improperly marked as described above in Paragraph 9; (ii Centurion failed to perform a stock locate for the stock trades described above in Paragraph 10 and (iii Centurion failed to accurately reflect Centurion s current members and ownership structure as described above in Paragraph In or about March 2006, DiMaggio failed to monitor the accuracy of Centurion s net capital computations as described above in Paragraph 12. FINDINGS

4 15. The acts, practices and conduct described in Paragraph 8 above constitute a violation of Exchange Rules 4.2, 15.1, Section 17(a of the Act and Rules 17a-3 and 17a-4 thereunder, by Centurion, in that Centurion improperly marked its stock activity when Centurion s stock activity recorded on its Trade Blotter did not accurately reflect the stock activity recorded in Centurion s Net Position Records and Haircut Report. 16. The acts, practices and conduct described in Paragraph 9 above constitute a violation of Exchange Rules 4.2; SEC Regulation SHO and Rule 200 thereunder, by Centurion, in that Centurion improperly marked 105 of 319 trades, of which 98 of 158 short sale stock trades, or 62%, were improperly marked as sell long instead of sell short when Centurion was not long the position. 17. The acts, practices and conduct described in Paragraph 10 above constitute a violation of Exchange Rules 4.2; SEC Regulation SHO and Rule 203 thereunder, by Centurion, in that Centurion failed to perform a stock locate for any of the short sale stock transactions described above in Paragraph The acts, practices and conduct described in Paragraph 11 above constitute a violation of Exchange Rules 3.7, 4.2, 15.1, Section 17(a of the Act and Rules 17a-3 and 17a-4 thereunder, by Centurion, in that Centurion failed to update its form BD on Web CRD to accurately reflect Centurion s current members and current ownership percentages. 19. The acts, practices and conduct described in Paragraph 12 above constitute a violation of Exchange Rules 4.2, 15.1, Section 15(c of the Act and 15c3-1 thereunder, Section 17(a of the Act and Rules 17a-3 and 17a-5 thereunder, by Centurion, in that Centurion overstated its net capital by $5,243,739 or approximately 844%. 20. The acts, practices and conduct described in Paragraph 13 above constitute a violation of Exchange Rule 4.2 by Anderson, in that Anderson failed to monitor the accuracy of Centurions books and records when (i Centurion s trades were improperly marked as described above in Paragraph 9; (ii Centurion failed to perform a stock locate for the stock trades described above in Paragraph 10 and (iii Centurion failed to accurately reflect Centurion s current members and ownership structure as described above in Paragraph The acts, practices and conduct described in Paragraph 14 above constitute a violation of Exchange Rule 4.2 by DiMaggio, in that DiMaggio failed to monitor the accuracy of Centurion s net capital computations as described above in Paragraph 12. SANCTION The sanction to be imposed shall consist of a twenty thousand dollar ($20,000 joint and several fine and a censure of each Subject. Subjects acknowledges that they have read the foregoing Letter of Consent, that no promise or inducement of any kind has been made to them by the Exchange or its staff, and that this Letter of Consent is voluntary on its part. Subjects understand and acknowledge that the Committee's decision in this matter will become part of its disciplinary record and may be considered in any future Exchange proceeding.

5 Subjects also acknowledge that the Committee's decision to accept or reject this Letter of Consent is final, and that it may not seek review thereof in accordance with Exchange Rule February 21, 2007 By: Date Centurion Securities, LLC Title: Gary Anderson Victor DiMaggio III