NOTICE OF DISCIPLINARY ACTION

MEMBER:

DV Trading LLC

CBOT RULE VIOLATION:

562. Position Limit Violations

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement in which DV Trading LLC (“DV”) neither admitted nor denied the rule violations upon which the penalty is based, on December 13, 2016, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“BCC” or “Panel”) found DV was subject to the BCC’s jurisdiction pursuant to Rules 400 and 402. The Panel also found that at the close of business on June 29, 2016, DV held a futures equivalent position of 985 long July 2016 Soybean Oil futures contracts, which was 445 contracts (82.41%) over the spot month position limit in effect. Within milliseconds of the opening of trade date June 30, 2016 (between 7:00:00.018 PM and 7:00:00.023 PM of calendar date June 29, 2016), DV liquidated its overage position, resulting in profits of $2,670. The Panel found that as a result, DV violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered DV to pay a fine of $25,000 and disgorge profits in the amount of $2,670.

EFFECTIVE DATE:

December 15, 2016