NOTICE OF DISCIPLINARY ACTION

MEMBER:

Noble Resources Pte. Ltd. (now known as Cofco Resources Pte. Ltd.)

CBOT RULE VIOLATION:

Rule 539. Prearranged, Pre-negotiated and Noncompetitive Trades Prohibited (in part)

A. General Prohibition

No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction . . . .

FINDINGS:

Pursuant to an offer of settlement in which Noble Resources Pte. Ltd. (at the time of the acts in question, a wholly-owned subsidiary of the Noble Group Limited, later renamed Cofco Resources Pte. Ltd. to reflect a subsequent change in its ownership, (“NRPL”)) neither admitted nor denied the rule violation upon which the penalty is based, on October 25, 2016, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that NRPL was subject to the jurisdiction of the Exchange pursuant to Rules 402 and 418. The Panel also found that on several occasions between December 2012 and February 2013, traders employed by NRPL engaged in pre-execution communications with traders employed by a counterparty about Soybean futures hedges associated with the execution of Prepaid Soybean Swap agreements. While pre-execution communications are allowed in the execution of off-exchange privately-negotiated transactions such as swap agreements, the Panel found that the communications, which specified details such as the contract, side of the market, time of execution, price and quantity to be executed, related to the execution of Soybean futures transactions on Globex. Such communications are not allowed in Agricultural futures products, and the Panel thus concluded that NRPL thereby violated CBOT Rule 539.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered NRPL to pay a fine of $75,000.

EFFECTIVE DATE:

October 27, 2016