NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 07-72997-BC and CBOT 08-00188-BC

MEMBER:

Joel Riechers (JRR)

CBOT RULE VIOLATIONS:

Legacy 350.05 TRADING PRACTICES

(a) No person shall purchase any futures contract, purchase any call option or sell any put option for his own account, or for any account in which he has an interest or for an account over which he has discretionary trading authority, while in possession of any executable order of another person for the purchase of any futures contract, the purchase of any call option or the sale of any put option in the same product.

(b) No person shall sell any futures contract, sell any call option or purchase any put option for his own account, or for any account in which he has an interest, or for an account over which he has discretionary trading authority, while in possession of any executable order of another person for the sale of any futures contract, the sale of any call option or the purchase of any put option in the same product.

532. DISCLOSING ORDERS PROHIBITED

No person shall disclose another person's order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. An order for pit execution is not considered public until it has been bid or offered by open outcry. No person shall take action or direct another to take action based on non-public order information, however acquired. The mere statement of opinions or indications of the price at which a market may open or resume trading does not constitute a violation of this rule.

FINDINGS:

Pursuant to an offer of settlement in which Joel Riechers neither admitted nor denied the findings and conclusions herein, on April 5, 2011 a Panel of the CBOT Business Conduct Committee (the “Panel”) made the following findings: that on more than one occasion from March 2007 through October 2007 Riechers inadvertently traded ahead of his customer orders. In so doing, Riechers violated Legacy CBOT Rule 350.05(a,b).

The Panel further found that on October 10, 2008 and December 5, 2008 Riechers entered into trades opposite a broker based on order information unavailable to other market participants. In so doing, Riechers violated CBOT Rule 532.

PENALTY:

In accordance with the settlement offer, the Panel fined Riechers $7,675, ordered him to pay restitution to his customers in the amount of $12,325 and serve a 10 days business day suspension of his 1) membership privileges; 2) access to all CME Group Inc. trading floors, and 3) direct access to all CME Group Inc. electronic trading and clearing platforms. The suspension will run from April 7, 2011 through April 20, 2011, inclusive

EFFECTIVE DATE:

April 7, 2011