NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8605-BC

MEMBER:

David Keyte

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;

T. to engage in dishonorable or uncommercial conduct.

FINDINGS:

Pursuant to an offer of settlement in which David Keyte (“Keyte”) neither admitted nor denied the rule violations upon which the penalty is based, on November 18, 2014, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that it had jurisdiction over Keyte pursuant to Rules 400 and 402 as the conduct occurred while Keyte was a CBOT member, and that between January 2, 2012, through April 16, 2012, Keyte entered orders in various Agricultural contracts on the 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 cancellation of these orders caused fluctuations in the publicly displayed Indicative Opening Price (“IOP”). The Panel concluded that Keyte thereby violated CBOT Rules 432.Q. and 432.T.

PENALTY:

In accordance with the settlement offer, the Panel ordered Keyte to pay a fine of $15,000. The Panel also suspended Keyte from accessing any CME Group Inc. trading floor, and direct access to all electronic trading and clearing platforms owned or controlled by CME Group for five business days, beginning on November 20, 2014, and continuing through and including November 26, 2014.

EFFECTIVE DATE:

November 20, 2014