NOTICE OF DISCIPLINARY ACTION

MEMBER:                        

Eagle Seven LLC

CBOT RULE VIOLATIONS:                  

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

Any positions, including positions established intraday, 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 Eagle Seven LLC (“Eagle Seven”) neither admitted nor denied the rule violation or factual findings upon which the penalty is based, on September 3, 2020, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that on trade date April 15, 2019, Eagle Seven purchased May-July 2019 Soybean Oil spreads that created intraday positions of long 9,103 MAY19 Soybean Oil contracts and short 9,094 JULY19 Soybean Oil contracts, which were 1,103 contracts (13.79%) and 1,094 contracts (13.68%) over the single month limit, respectively. The next day, Eagle Seven briefly held an intraday long position of 8,023 MAY19 Soybean Oil contracts, which was 23 contracts (.29%) over the single month position limit. After recognizing it was over the limit on each occasion, Eagle Seven liquidated its overages to bring its positions into compliance and did not profit from doing so.

The Panel concluded that Eagle Seven thereby violated CBOT Rule 562.

PENALTY:                         

In accordance with the settlement offer, the Panel ordered Eagle Seven to pay a fine of $20,000.

EFFECTIVE DATE:                               

September 8, 2020