NOTICE OF DISCIPLINARY ACTION

MEMBER FIRM:

Two Sigma Investments, LP

CBOT RULE VIOLATION:

Rule 562 (“Position Limit Violations”) (in part)

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 Two Sigma Investments, LP (“Two Sigma”) neither admitted nor denied the rule violation upon which the penalty is based, on March 28, 2017, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that at the end of trading on February 22, 2016, accounts managed by Two Sigma and its affiliate, whose positions were aggregated, held a CBOT Wheat futures position of 12,867 short contracts, 867 contracts, or 7.22%, over the all month speculative position limit. The next day, Two Sigma and its affiliate reached an aggregated maximum short position of 12,953 contracts, 953 contracts, or 7.94%, over the all month speculative position limit. Upon discovering the overage on the morning of February 23, 2016, Two Sigma and its affiliate liquidated the overage to bring the aggregate position into compliance with the all month limit, and did not profit from doing so. The Panel concluded that Two Sigma thereby violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Two Sigma to pay a fine of $25,000.

EFFECTIVE DATE:

March 30, 2017