NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:              

DairyAmerica Inc.

CME 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 DairyAmerica Inc. (“DairyAmerica”) neither admitted nor denied the rule violation or factual findings upon which the penalty is based, on April 22, 2021, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that at the close of trading on February 5, 2020, DairyAmerica held a net futures equivalent short position of 1,035.641 April 2020 CME Non-fat Dry Milk Futures (“NDM”) contracts, which exceeded the single month position limit by 35.641 contracts, or 3.56%. On the following trade date, February 6, 2020, prior to realizing it was over the limit, DairyAmerica increased its April 2020 NDM position to 1,060.641 short April 2020 NDM contracts, or 6.064% over the single month position limit. DairyAmerica liquidated its overage to bring its positions into compliance and did not profit from doing so.

The Panel concluded that DairyAmerica thereby violated CME Rule 562.

PENALTY:                         

In accordance with the settlement offer, the Panel ordered DairyAmerica to pay a fine of $15,000.

EFFECTIVE DATE:                               

April 26, 2021