NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 10-04526-BC

MEMBER:

BUNGE CHICAGO, INC.

CBOT RULE VIOLATION:

854. CONCURRENT LONG AND SHORT POSITIONS

Set forth below are the procedures that must be followed for concurrent long and short positions and hold-open accounts.

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D. The Exchange takes no position regarding the internal bookkeeping procedures of its clearing members which, for the convenience of a customer, may "hold open" a position only on their books. However, the clearing member must accurately report to the Exchange and the Clearing House, as appropriate, large trader positions, long positions eligible for delivery and open interest.

FINDINGS:

Pursuant to an offer of settlement in which Bunge Chicago, Inc. (“Bunge”) neither admitted nor denied the findings, on February 23, 2011, a Panel of the CBOT Business Conduct Committee (the “Panel”) made the following findings: Due to a series of internal errors, Bunge misreported its large trader positions and its open long positions for open interest in the December 2009 Soybean Meal futures contract going into the final trade date prior to the contract’s expiration. The Panel found that in so doing Bunge violated CBOT Rule 854.

PENALTY:

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

EFFECTIVE DATE:

February 25, 2011