NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 12-8892-BC

NON-MEMBER:

The DeLong Co., Inc.
 

CBOT RULE VIOLATIONS:

562. POSITION LIMIT VIOLATIONS (in part)

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations. Additionally, any person making a bid or offer that would, if accepted, cause such person to exceed the applicable position limits shall be in violation of this rule.

FINDINGS:

Pursuant to an offer of settlement in which non-member The DeLong Co., Inc. (“DeLong”) neither admitted nor denied the rule violation upon which the penalty is based, and after DeLong voluntarily submitted itself to the jurisdiction of the BCC for purposes of settling this matter, on February 14, 2013, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“BCC”) found that on April 27, 2012, DeLong held a long position of 1,358 May 2012 Soybean futures contracts, which was 301 contracts, or 28%, over its Exchange- approved expiration month hedge exemption level of 1,057 contracts based upon its actual cash-market position. DeLong did not benefit financially from the violation and subsequently took measures to ensure that spot month position limits are not violated. The Panel found that as a result, DeLong violated CBOT Rule 562 (Position Limit Violations).

PENALTY:

In accordance with the settlement offer, the Panel fined DeLong $25,000.

EFFECTIVE DATE:

February 19, 2013