NOTICE OF DISCIPLINARY ACTION

CHICAGO BOARD OF TRADE

NOTICE OF DISCIPLINARY ACTION

FILE NO.: 15-CH-1504

MEMBER FIRM: Macquarie Futures USA LLC

CBOT RULE: 970. FINANCIAL REQUIREMENTS

A.            Subject to exemptions granted by Exchange staff, all clearing members, including non- FCMs, must comply with the requirements set forth in CFTC Regulations 1.10, 1.12, 1.17 and 1.18. This includes, but is not limited to, the following:

1.             Maintenance of minimum capital requirements of at least $5 million except that a clearing member that is a bank must maintain minimum Tier I Capital (as defined in accordance with regulation applicable to the relevant bank) of at least $5 billion;                                                                        

FINDINGS: Pursuant to an offer of settlement in which Macquarie Futures USA LLC neither admitted nor denied the rule violation upon which the penalty is based, on December 10, 2015, the Clearing House Risk Committee found that Macquarie Futures USA violated CBOT Rule 970.A.1.

PENALTY: In accordance with the settlement offer, the Committee imposed a $25,000 fine.

EFFECTIVE DATE: December 11, 2015