NOTICE OF DISCIPLINARY ACTION

MEMBER:

Joshua Kirley

CBOT RULE VIOLATION:

Rule 562. Position Limit Violations (in part)

Any positions, including positions established intraday, in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement in which Joshua Kirley (“Kirley”) neither admitted nor denied the rule violations upon which the penalty is based, on August 12, 2015, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that it had jurisdiction over Kirley pursuant to Rules 400 and 402 as the conduct occurred while Kirley was a CBOT member, and that on November 30, 2012, accounts controlled by Kirley carried a position of 866 contracts long in December 2012 Corn Futures, which exceeded the spot month speculative position limit of 600 contracts by 266 contracts, or approximately 44.3%. Kirley liquidated his overage position on November 30, 2012, and realized a profit of $4,364.45. The Panel concluded that Kirley thereby violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Kirley to pay a fine of $20,000, and to disgorge profits of $4,364.45.

EFFECTIVE DATE:

August 14, 2015