NOTICE OF DISCIPLINARY ACTION

MEMBER:

Credit Suisse Securities (USA) LLC

CBOT RULE VIOLATION:

432 - General Offenses

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 or good name of the Exchange.

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

FINDINGS:

Pursuant to an offer of settlement in which Credit Suisse Securities (USA) LLC (“Credit Suisse”) neither admitted nor denied the rule violation upon which the penalty is based, on January 20, 2015, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that it had jurisdiction over Credit Suisse pursuant to Rules 400 and 402 as the conduct occurred while Credit Suisse was a CBOT member.

The also Panel found that on December 14, 2012, Credit Suisse operated an automated trading system (“ATS”) that malfunctioned and caused an excessive number of orders and cancel messages to be entered in the March 2013 Two-Year futures contract on the Globex electronic trading platform. Although Credit Suisse became aware of the malfunction immediately, it allowed the ATS to continue to operate for 90 minutes while attempting to identify the cause and rectify the problem. During those 90 minutes, the ATS accounted for 88% of the messaging volume in the contract. Credit Suisse ultimately deactivated the ATS only after the Exchange contacted the firm regarding the messaging activity. The Panel concluded that, as a result, Credit Suisse violated CBOT Rules 432.Q. and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Credit Suisse to pay a fine of $175,000.

EFFECTIVE DATE:

January 22, 2015