NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 08-00145-BC

NON-MEMBER:

Michael Stefanski

(LEGACY) CBOT REGULATION:

9B.14 Good Faith Bids and Offers

A member or Registered User shall not knowingly enter, or cause to be entered, bids or offers into the e-cbot system other than in good faith for the purpose of executing bona fide transactions.

CBOT RULE:

534. Wash Sales Prohibited

No person shall place for the same beneficial owner buy and sell orders for the same product and expiration month, and for a put or call option, the same strike price, at or about the same time with the intent to avoid a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders placed for the same beneficial owner in the same product and expiration month ….must be entered in good faith for the purpose of executing bona fide transactions that result in a change of ownership….

FINDINGS:

Pursuant to an offer of settlement in which Michael Stefanski neither admitted nor denied the findings, on January 20, 2010, a panel of the CBOT Business Conduct Committee found that on September 17, 2007, in Treasury Bond futures and on December 19, 2007, in Federal Fund futures Stefanski entered on the electronic trading platform a total of four pairs of buy and sell orders late in the delivery period that matched opposite each other for accounts that had the same beneficial owner:

PENALTY:

In accordance with the settlement offer, the Panel fined Stefanski $25,000.

EFFECTIVE DATE:

January 22, 2010