NOTICE OF DISCIPLINARY ACTION

MEMBER:

E. Davison Massey

CBOT VIOLATION:

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.

FINDINGS:

Pursuant to an unsupported offer of settlement in which E. Davison Massey (“Massey”) neither admitted nor denied the rule violation upon which the penalty is based, on September 18, 2014, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that it had jurisdiction over Massey pursuant to Rules 400 and 402 as the conduct occurred while Massey was a CBOT member. The Panel further found that on trade date December 4, 2012, Massey had an end of day position of 754 contracts short in December 2012 Corn (“Dec 12 Corn”) futures, which exceeded the spot month speculative position limit of 600 contracts by 154 contracts, or approximately 25.7%. On trade date December 5, 2012, Massey attempted to correct the overage by buying 504 Dec 12 Corn futures, but made an error and accidentally sold 504 contracts. As a result, Massey had an intraday position of 1,258 contracts short in Dec 12 Corn futures, which exceeded the spot month speculative position limit of 600 contracts by 658 contracts, or approximately 110%. Massey immediately corrected the error and came into compliance, suffering a loss in the process. The Panel found that, in committing these actions, Massey violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Massey to pay a fine in the amount of $10,000.

EFFECTIVE DATE:

December 23, 2014