NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 10-7849-BC

NON-MEMBER:

Paul F. Glenn

CBOT RULE VIOLATIONS:

(Legacy) Rule 443. Position Limit Violations (in part)

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.

(Legacy) Rule 14102.E. Position Limits (Wheat Futures) (in part)

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

3. 6,500 futures-equivalent contracts net long or net short in all months combined.

FINDINGS:

Pursuant to an offer of settlement in which Paul F. Glenn (“Glenn”) neither admitted nor denied the rule violations upon which the penalty is based, on July 2, 2012, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on November 11, 2010, Glenn, due to an error in which a broker sold the wrong contract, held a net short position of 6,682.034 futures-equivalent contracts, which exceeded the all-months-combined speculative position limit of 6,500 contracts by 182.034 contracts. These excess positions were subsequently liquidated during the opening minutes of trading the following day.

The Panel found that in so doing, Glenn violated (Legacy) CBOT Rule 443 (Position Limit Violations).

PENALTY:

In accordance with the settlement offer and its findings, the Panel ordered Glenn to pay a $10,000 fine, and disgorge profits in the amount of $51,021.28.

EFFECTIVE DATE:

July 5, 2012