NOTICE OF DISCIPLINARY ACTION

MEMBER:

Kershner Commodity Trading Group

CBOT RULE VIOLATIONS:

Rule 562. (“Position Limit Violations”) (in relevant 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 Kershner Commodity Trading Group neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on October 5, 2023, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that at the close of business on June 29, 2022, Kershner held a July 2022 Soybean Futures position that was in excess of the spot month position limit of 1,200 contracts. Specifically, Kershner held a futures equivalent position of 1,799 short JULY22 Soybean contracts, which was 599 contracts (49.92%) over the standard position limit in effect for the trade date June 30, 2022. In addition, on June 30, 2022, Kershner held an end of day futures equivalent short position of 1,382 JULY22 Soybeans, 182 contracts (15.17%) over the spot month position limit of 1,200 contracts.

The Panel concluded that as a result of the foregoing, Kershner violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Kershner to pay a fine of $30,000.