NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:          

Altshuler Shaham

CBOT RULE VIOLATIONS:                   

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 Altshuler Shaham neither admitted nor denied the rule violation upon which the penalty is based, on April 22, 2021, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that at the close of business on June 8, 2020, Altshuler held a total futures equivalent long position of 13,197 Wheat futures contracts, which was 1,193 contracts  (9.94%) over the all-month position limit of 12,000 contracts. On June 10, 2020, Altshuler liquidated its overage to bring its position into compliance. The Panel found that Altshuler violated CBOT Rule 562.

PENALTY:          

In accordance with the settlement offer, the Panel ordered Altshuler to pay a fine in the amount of $25,000.

EFFECTIVE DATE:                

April 26, 2021