NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 17-0743-BC

NON-MEMBER FIRM:

 Polar Star Management 

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, including positions established intraday.

FINDINGS:

Pursuant to an offer of settlement in which Polar Star Management (“Polar Star”) neither admitted nor denied the rule violation upon which the penalty is based, on July 24, 2018, a Panel of the CBOT Business Conduct Committee (“Panel”) found that at the close of business on July 10, 2017, Polar Star held a total combined position of 12,229 contracts short in CBOT Wheat futures contracts, which was 229 contracts, or 1.9%, in excess of the all month position limit of 12,000 contracts in effect. On July 11, 2017, Polar Star liquidated its overage to bring its position into compliance, resulting in a profit of $7,420.60. The Panel concluded that Polar Star thereby violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Polar Star to pay a fine of $10,000 and disgorgement in the amount of $7,420.60.

EFFECTIVE DATE:

July 26, 2018