NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 10-07943-BC

MEMBER:

Miles McKerr (MCM)
 

CBOT RULE VIOLATIONS:

Rule 562. Position Limit Violations (in part)

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations. Additionally,any person making a bid or offer that would,if accepted, cause such a person to exceed the applicable position limits shall be in violation of this rule.

Rule 10102.E. Position Limits (Corn Futures) (in part)

In accordance with Rule 559., Position Limits and Exemptions,no person shall own or controlpositions in excess of:

1.600 contracts net long or net short in the spot month.

FINDINGS:

Pursuant to an offer of settlement in which Miles McKerr neither admitted nor denied the rule violations upon which the penalty is based, on March 15,2012, a Panel of the CBOT Business Conduct Committee found that on trade date November 30,2010,McKerr failed to adhere to the spot month speculative position limit for Corn futures by entering orders to purchase a total of 1,500 December- March Corn futures spreads. At the time of placing these bids, McKerr had a resting order to purchase 200 December- March Corn futures spreads and an established long December Corn futures position of 159 contracts.These offers,if accepted,would have caused McKerr to exceed the spot month speculative position limit of 600 contracts by 1,259 contracts.The Panel found that in so doing,McKerr violated CBOT Rule 562 (Posti ion Limit Violations) and CBOT Rule 10102.E (Corn Futures, Position Limits).

PENALTY:

In accordance with the settlement offer,the Panel fined McKerr $15,000.

EFFECTIVE DATE:

March 19,2012