NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 09-03219-BC

MEMBER:

John Zanutto (BBQ)

CBOT RULE VIOLATION:

530. PRIORITY OF CUSTOMERS’ ORDERS

A member shall not buy (sell) a futures contract, buy (sell) a call option or sell (buy) a put option for his own account, an account in which he has a direct or indirect financial interest, or an account over which he has discretionary trading authority when he is in possession of an executable order for another person to buy (sell) a futures contract, buy (sell) a call option or sell (buy) a put option in the same product, regardless of the venue of execution. All contract months in a given futures product and all options on the futures product, in addition to any corresponding alternative sized (mini or micro) futures or options contracts on a given product, shall be considered the same product for the purposes of this rule.

FINDINGS:

Pursuant to an offer of settlement in which John Zanutto neither admitted nor denied the rule violations upon which the penalty is based, on October 6, 2011, a panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee found that on two occasions between August 6, 2008, and August 13, 2008, Zanutto traded for his personal account ahead of, and at a better price than executable customer orders in his possession. The Panel found that in so doing, Zanutto violated CBOT Rule 530 (Priority of Customer Orders).

PENALTY:

In accordance with the settlement offer, the Panel fined Zanutto $7,500 and also suspended Zanutto’s direct access to any CME Group trading or clearing platform for one year beginning on the effective date below. In addition, the Panel barred Zanutto from applying for any CME Group exchange membership for one year, also beginning on the effective date below. Zanutto’s suspension will run from the October 10, 2011 through October 10, 2012, inclusive.

EFFECTIVE DATE:

October 10, 2011