NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 18-0918-BC

MEMBER:

SPX Equities Gestão De Recursos Ltda.

CBOT RULE VIOLATION: Rule 562 (“Position Limit Violations”) (in relevant 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 SPX Equities Gestão De Recursos Ltda. (“SPX”) neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on May 23, 2019, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that at the close of business on trade date April 4, 2018, SPX held an aggregate net futures equivalent long position of 34,791 December 2018 Corn futures contracts, which exceeded the single month and all-months position limit by 1,791 contracts, or 5.42%. On trade date April 5, 2018, SPX liquidated 200 contracts and at the close of business reported an aggregate net futures equivalent long position of 34,591 December 2018 Corn futures contracts, which exceeded the single month and all-months position by 1,591 contracts, or 4.82%. On trade date April 6, 2018 (calendar date April 5, 2018), upon learning of the overage, SPX liquidated its position to bring its position into compliance, which resulted in $221,009.40 in profits.

The Panel concluded that SPX thereby violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered SPX to pay a fine of $20,000 and disgorgement of $221,009.40.

EFFECTIVE DATE:

May 28, 2019