NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 12-8898-BC

MEMBER:

MICHAEL ROSENSON

CBOT RULE VIOLATION:

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 of good name of the Exchange;
T. to engage in dishonorable or uncommercial conduct;

FINDINGS:

Pursuant to an offer of settlement in which Michael Rosenson neither admitted nor denied the rule violations upon which the penalty is based, on February 11, 2014, a Panel of the CBOT Business Conduct Committee found that on one or more occasions between January 1, 2012, and May 20, 2012, Michael Rosenson 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 Michael Rosenson thereby violated CBOT Rules 432.Q. and 432.T.

PENALTY:

In accordance with the settlement offer, the Panel fined Michael Rosenson $40,000.

EFFECTIVE DATE:

February 13, 2014