NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 09-03090-BC

MEMBER:

JOSH OLEARI (VPO)

CBOT RULE VIOLATION:

(Legacy) 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 Josh Oleari (“Oleari”) neither admitted nor denied the findings, on February 3, 2011, a Panel of the CBOT Business Conduct Committee (the “Panel”) made the following findings: On several dates during the October 2007 delivery month, Oleari executed 21 transactions on the e-cbot electronic trading platform in the Soybean Oil and Soybean Meal futures markets where he was both the buyer and seller to the transaction for the purpose of freshening long position dates. The Panel found that in so doing Oleari violated (Legacy) CBOT Rule 9B.14

PENALTY:

In accordance with the settlement offer, the Panel fined Oleari $15,000 and suspended his membership privileges, access to any CME Group trading floors, and direct access to any CME Group electronic trading or clearing platform for 15 business days, beginning February 7, 2011 and continuing through February 28, 2011, inclusive.

EFFECTIVE DATE:

February 7, 2011