NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Manoj Jindal

CBOT RULE VIOLATIONS:

Rule 432 (“General Offenses”) (in part)

It shall be an offense:

B.2. to engage in conduct or proceedings inconsistent with just and equitable principles of trade;

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange.

FINDINGS:

Pursuant to an offer of settlement in which Manoj Jindal (“Jindal”) neither admitted nor denied the rule violations upon which the penalty is based, on October 4, 2016, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that it had jurisdiction over Jindal pursuant to CBOT Rules 400 and 402, as the conduct occurred while Jindal was an employee of a CBOT member. The Panel also found that on certain days during the months of July through November 2013, Jindal entered large orders in various Soybean futures contract markets in a manner suggesting that he did not have the intent to trade. The Panel specifically found that Jindal’s trading strategy involved activity in which Jindal placed a smaller order on one side of the market on the CME Globex electronic trading platform (“Globex”). Pursuant to the strategy, Jindal also subsequently entered multiple large-lot orders on the other side of the market at or near the best offer (bid) on Globex. Once the smaller order was executed, Jindal did, on a number of occasions, cancel the large orders. The Panel found that the execution of this strategy created the appearance of an imbalance in buy/sell pressure, and that the effect of this strategy was to induce other market participants to trade opposite his smaller resting orders.

The Panel concluded that Jindal thereby violated CBOT Rules 432.B.2. and 432.Q.

PENALTY:

In accordance with the settlement offer, the Panel ordered Jindal to pay a fine in the amount of $75,000 and to serve a 30-day suspension from accessing any CME Group Inc. trading floor and all direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc., including CME Globex. The suspension shall run from October 6, 2016, to November 5, 2016.

EFFECTIVE DATE:

October 6, 2016