NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 10-07755-BC

MEMBER:

Timothy Patrick Roach (ROK)

CBOT RULE VIOLATIONS:

(Legacy) Rule 443. Position Limit Violations
The Market Regulation Department and the BCC shall have the authority to enforce the position limit rules of the Exchange. For purposes of this rule, 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 13102.E. Position Limits (Soybean Meal Futures)
In accordance with Rule 559., Position Limits and Exemptions, no person shall own or control positions in excess of:

1. Seven hundred and twenty (720) contracts net long or net short in the spot month.

FINDINGS:

Pursuant to an offer of settlement in which Timothy Patrick Roach neither admitted nor denied the rule violations upon which the penalty is based, on June 16, 2011, a Panel of the CBOT Business Conduct Committee found that during the October 5, 2010, trading session, Roach failed to adhere to the spot month speculative position limits for Soybean Meal futures by inadvertently entering a single 1000-lot offer in the October – December 2010 Soybean Meal futures spread that would, if accepted, have caused him to exceed the applicable spot month speculative position limit of 720 contracts for the October 2010 Soybean Meal contract.

PENALTY:

In accordance with the settlement offer, the Panel fined Roach $12,500.

EFFECTIVE DATE:

June 20, 2011