NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 09-03407-BC

NON-MEMBER:

JAN STEPO

CBOT RULE VIOLATION:

534. WASH TRADES PROHIBITED

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent or negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

539. PREARRANGED, PRE-NEGOTIATED AND NON-COMPETITIVE TRADES PROHIBITED

A. No person shall prearrange or pre-negotiate any purchase or sale or non-competitively execute any transaction.

FINDINGS:

Pursuant to an offer of settlement in which Jan Stepo neither admitted nor denied the facts, on November 22, 2010, a panel of the CBOT Business Conduct Committee found that Jan Stepo voluntarily submitted himself to the jurisdiction of the CBOT Business Conduct Committee and that on several days in November 2008, December 2008, and January 2009, he engaged in a series of prearranged trades with two other nonmembers in the Globex® September and December 2009 30-Year U.S. Treasury Bond Futures. The transactions were designed to move money from one account to another. The Panel found that in so doing, Jan Stepo violated CBOT Rules 534 and 539.A.

PENALTY:

The Panel fined Jan Stepo $25,000 and suspended his direct access to any trading floor or electronic trading or clearing platform owned or operated by CME Group, including CME Globex® for 1 calendar year.

The suspension shall run from November 24, 2010 through November 24, 2011 inclusive.

EFFECTIVE DATE:

November 24, 2010