NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 12-8726-BC

MEMBER:

ABN AMRO Clearing Chicago LLC

CBOT RULE VIOLATION:

Rule 576. Identification Of Globex Terminal Operators

Each Globex terminal operator shall be identified to the Exchange, in the manner prescribed by the Exchange, and shall be subject to Exchange rules. If user IDs are required to be registered with the Exchange, it is the duty of the clearing member to ensure that registration is current and accurate at all times. Each individual must use a unique user ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using a user ID other than the individual’s own unique user ID.

FINDINGS:

Pursuant to an offer of settlement in which ABN AMRO Clearing Chicago LLC neither admitted nor denied the rule violations upon which the penalty is based, on October 28, 2014, a Panel of the CBOT Business Conduct Committee (“Panel”) found that it had jurisdiction over ABN AMRO Clearing Chicago LLC pursuant to CBOT Rules 400 and 402, as the conduct occurred while it was a Member firm. The Panel also found that on one or more occasions from 2010 through 2013, ABN AMRO Clearing Chicago LLC failed to properly register Tag 50 User IDs and allowed orders to be entered on Globex using incorrect Tag50 User IDs. The Panel concluded that in so doing, ABN AMRO Clearing Chicago LLC violated CBOT Rule 576.

PENALTY:

In accordance with the settlement offer, the Panel ordered ABN AMRO Clearing Chicago LLC to pay a fine of $3,920.

EFFECTIVE DATE:

October 30, 2014