NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 13-9401-BC

NON-MEMBER:

AQR CAPITAL MANAGEMENT LLC

CBOT RULE VIOLATIONS:

562. POSITION LIMIT VIOLATIONS

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

FINDINGS:

Pursuant to an offer of settlement AQR Capital Management LLC (“AQR”) presented at a hearing on October 22, 2013, in which AQR neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that AQR was subject to the jurisdiction of the Panel pursuant to Exchange Rule 418 and that on April 17, 2013, AQR exceeded the single month speculative position limit of 15,000 contracts in May 2013 Soybean futures by 323 contracts or approximately 2%. AQR realized a profit of $925.00 when it liquidated those contracts carried over the limit. This was AQR’s third position limit violation in a seven month period.

The Panel found that as a result, AQR violated Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered AQR to pay a fine to the Exchange in the amount of $70,000 and disgorge profits in the amount of $925.00.

EFFECTIVE DATE:

October 24, 2013