NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8472-BC

MEMBER:

Credit Suisse Asset Management

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 person to exceed the applicable position limits shall be in violation of this rule.

FINDINGS:

Pursuant to an offer of settlement in which Credit Suisse Asset management (“Credit Suisse”) neither admitted nor denied the rule violations upon which the penalty is based, on November 4, 2014, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that it had jurisdiction over Credit Suisse pursuant to Rules 400 and 402 as the conduct occurred while Credit Suisse was a CBOT member, and that at the close of trading on August 9, 2011, accounts controlled by Credit Suisse held positions in December 2011 Wheat Futures of 6,653 contracts long, which exceeded the single month speculative position limit of 6,500 contracts in effect at that time by 153 contracts, or approximately 2.35%. Further, at the close of trading on August 10, 2011, accounts controlled by Credit Suisse held positions in December 2011 Wheat Futures of 7,265 contracts long, which exceeded the single month speculative position limit of 6,500 contracts in effect at that time by 765 contracts, or approximately 11.8%. Last, the Panel found that on August 11, 2011, accounts controlled by Credit Suisse held positions in December 2011 Wheat Futures of 7,877 contracts long, which exceeded the single month speculative position limit of 6,500 contracts in effect at that time by 1,377 contracts, or approximately 21.2%. Credit Suisse subsequently liquidated these excess positions, which resulted in $98,623 in profits.

The Panel concluded that Credit Suisse thereby violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Credit Suisse to pay a fine of $22,500 and disgorgement of $98,623.

EFFECTIVE DATE:

November 6, 2014