NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 13-9289-BC

NON-MEMBER:

Ragasa Industrias, S.A. de C.V.

CBOT RULE VIOLATIONS:

Rule 432 (“General Offenses”) (in part)

It shall be an offense:

W. for a Member to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

Rule 534. Wash Trades Prohibited

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

FINDINGS:

Pursuant to an offer of settlement in which Ragasa Industrias, S.A. de C.V. (“Ragasa”) neither admitted nor denied the rule violations upon which the penalty is based, on July 24, 2014, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that Ragasa was subject to the jurisdiction of the Exchange under Rule 418, and that on numerous dates in December 2012, Ragasa executed 758 trades totaling 4,980 contracts in Soybean Futures in which Ragasa maintained ownership of the accounts on both sides of the transactions. Ragasa, acting through its employees, reasonably should have known that the trades would achieve a wash result – i.e., the purchase and sale of the same instrument at the same price for accounts with the same beneficial ownership. The Panel found that Ragasa failed to diligently supervise its employees in a manner sufficient to ensure that their conduct was consistent with Exchange rules.

The Panel concluded that Ragasa thereby violated CBOT Rules 432.W and 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Ragasa to pay a fine of $60,000.

EFFECTIVE DATE:

July 28, 2014