NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8477-BC

MEMBER:

Anuj C. Singhal

CBOT RULE VIOLATIONS:

Rule 432. General Offenses

It shall be an offense:

B.2. to engage in conduct or proceedings inconsistent with just and equitable principles of trade;

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;

T. to engage in dishonorable or uncommercial conduct.

FINDINGS:

Pursuant to an offer of settlement in which Anuj C. Singhal (“Singhal”) neither admitted nor denied the rule violations upon which the penalty is based, on September 18, 2014, a Panel of the CBOT Business Conduct Committee (“BCC” or “Panel”) found that it had jurisdiction over Singhal pursuant to CBOT Rules 400 and 402 as the conduct at issue occurred while Singhal was a CBOT member. The Panel also found that during June through August 2011, Singhal engaged in a pattern of activity wherein he entered large orders in Agricultural futures contracts on the CME Globex electronic trading platform without the intent to trade. The Panel specifically found that Singhal would enter large orders for the purpose of obtaining favorable fills on smaller orders on the other side of the order book. Singhal would then fully cancel the large orders after his smaller orders began trading. In determining Singhal’s intent to trade the large orders that were fully canceled, the Panel took into consideration the significant imbalance these orders created between the volume on the bid and offer, the percentage of large orders canceled, and the exposure time of the fully canceled orders. The Panel concluded that Singhal thereby violated CBOT Rules 432.B.2., 432.Q., and 432.T.

PENALTY:

In accordance with the settlement offer, the Panel fined Singhal $60,000 and suspended his membership privileges, access to any CME Group trading floor, and direct or indirect access to any CME Group electronic trading or clearing platform for three months, beginning on the effective date below and continuing through and including December 22, 2014.

EFFECTIVE DATE:

September 22, 2014