NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 07-ETI-65-BC

MEMBER:

JONATHAN ARMSTRONG (JAR)

LEGACY CBOT REG. VIOLATION:

9B.13 Trading Against Customer Orders and Crossing Orders

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(c) Pre-Execution Communications Prohibited

(i) Pre-execution communications are communications between two
market participants for the purpose of discerning interest in the
execution of a transaction prior to the entry of an order

(ii) Pre-execution communications and transactions arising from such
communications are prohibited….

FINDINGS:

Pursuant to an offer of settlement in which Jonathan Armstrong neither admitted nor denied the rule violations upon which the penalty is based, on October 6, 2010, a Panel of the CBOT Business Conduct Committee found that on February 7, 2007, Armstrong engaged in pre-execution discussions concerning 11 different transactions in various electronically traded CBOT products. In so doing, the Panel found that Armstrong violated legacy CBOT Regulation 9B.13.

PENALTY:

In accordance with the settlement offer the Panel fined Armstrong $10,000.

EFFECTIVE DATE:

October 8, 2010