FILE NO.:

CBOT 11-8430-BC

MEMBER:

JOSEPH LALICH

CBOT RULE VIOLATION:

RULE 432 GENERAL OFFENSES (in part)

It shall be an offense:

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange.

FINDINGS:

Pursuant to an offer of settlement in which Lalich neither admitted nor denied the rule violation upon which the penalty is based, on March 14, 2013, a Panel of the CBOT Business Conduct Committee (the “Panel”) found that on one or more occasions from February through September 2011, Lalich entered Soybean and Corn Futures spread orders on the CME Globex electronic trading platform during the pre-opening session that were not made in good faith for the purpose of executing bona fide transactions. The entry and subsequent cancellation of these orders caused fluctuations in the publically displayed Indicative Opening Price (“IOP”). The Panel found that in so doing, Lalich violated CBOT Rule 432.Q.

PENALTY:

In accordance with the settlement offer, the Panel ordered Lalich to pay a fine of $20,000 and have his access to all CME Group trading floors and direct access to all electronic trading and clearing platforms owned or controlled by CME Group suspended for 15 Business Days.

EFFECTIVE DATE:

March 18, 2013