NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 11-8733-BC

MEMBER:

Alexander Kottoulas

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 Alexander Kottoulas (“Kottoulas”) neither admitted nor denied the rule violations upon which the penalty is based, on July 24, 2014, a Panel of the CBOT Business Conduct Committee found that it had jurisdiction over Kottoulas pursuant to Rules 400 and 402 as the conduct occurred while Kottoulas was a CBOT member, and that on one or more occasions between August 29, 2011, and December 1, 2011, Kottoulas 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 Kottoulas thereby violated CBOT Rules 432.Q. and 432.T.

PENALTY:

In accordance with the settlement offer, the Panel ordered Kottoulas to pay a fine of $15,000. The Panel also barred Kottoulas 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 20 business days, beginning on the effective date below and continuing through and including August 22, 2014.

EFFECTIVE DATE:

July 28, 2014