NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8680-BC

MEMBER:

Carl Graves

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 Carl Graves (“Graves”) neither admitted nor denied the rule violations upon which the penalty is based, on February 27, 2014, a Panel of the CBOT Business Conduct Committee found that on one or more occasions between November 15, 2011, and March 20, 2012, Graves entered orders in various Agricultural contracts 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 cancelation of these orders caused fluctuations in the publicly displayed Indicative Opening Price (“IOP”). The Panel concluded that Graves thereby violated CBOT Rules 432.Q. and 432.T.

PENALTY:

In accordance with the settlement offer, the Panel ordered Graves to pay a fine of $20,000. The Panel also barred Graves from accessing any CME Group Inc. trading floor, and direct access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. for 25 days, beginning on the effective date below and continuing through and including March 27, 2014.

EFFECTIVE DATE:

March 3, 2014