NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8668-BC

MEMBER:

Edward V. Ficht

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 Edward V. Ficht (“Ficht”) neither admitted nor denied the rule violation upon which the penalty is based, on April 7, 2014, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that Ficht is subject to the jurisdiction of the Exchange because at the time of the transaction at issue he was an employee of a member firm, and that during October and November 2011, Ficht utilized an automated trading system (“ATS”) which entered an excessive number of orders, cancelations, and price modifications in the December 2011/March 2011 Corn futures spread instrument and the January 2012/May 2012 Soybean futures spread instrument. Although Ficht observed the aberrant activity, Ficht continued to employ the ATS without taking remedial measures. In addition, Ficht did not have any measures or controls in place to identify or prevent the activity.

The Panel concluded that Ficht thereby violated CBOT Rule 432.Q .

PENALTY:

In accordance with the settlement offer, the Panel ordered Ficht to pay a fine of $20,000 and barred Ficht from accessing all CME Group Inc. trading floors, and access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. for five business days, beginning on April 9, 2014, and continuing through and including April 15, 2014.

EFFECTIVE DATE:

April 9, 2014