NOTICE OF DISCIPLINARY ACTION

11-CH-1107

EXCHANGE DISCIPLINARY ACTION

CLEARING MEMBER: Cunningham Commodities, LLC

CBOT RULE VIOLATIONS: 930.F.  Release of Excess Performance Bond

Subject to exceptions granted by Clearing House staff, clearing members may only release performance bond deposits from an account if such deposits are in excess of initial performance bond requirements.

FINDINGS: Pursuant to an offer of settlement in which Cunningham Commodities, LLC neither admitted nor denied the violation, the Clearing House Risk Committee found that Cunningham Commodities, LLC violated the above rule.

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

EFFECTIVE DATE: January 6, 2012