NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 08-00741-BC

NON-MEMBER:

CHINATRUST COMMERCIAL BANK

LEGACY CBOT REGULATION VIOLATIONS:

350.05. TRADING PRACTICES

f. No person shall make any purchase or sale which has been prearranged, except as permitted under regulations 331.05, 331.06 and 331.08.

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.

FINDINGS:

Pursuant to an offer of settlement in which Chinatrust Commercial Bank neither admitted nor denied the rule violations upon which the penalty is based, on February 23, 2011, a panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on October 30, 2007 and October 31, 2007, two employees of Chinatrust entered opposing buy and sell orders onto e-cbot electronic trading platform with the knowledge and intent that the orders would match opposite one another for accounts owned by the same beneficial owner. The orders were entered other than in good faith and not for the purpose of executing bona fide transactions. The Panel found that in doing so Chinatrust violated legacy CBOT Regulations 350.05(f) and 9B.14.

PENALTY:

In accordance with the settlement offer and in consideration of Chinatrust’s enhanced compliance procedures since implemented, the Panel fined Chinatrust Commercial Bank $40,000.

EFFECTIVE DATE:

February 25, 2011