NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 13-9567-BC

MEMBER:

BNP Paribas Securities Corp.

CBOT RULE VIOLATIONS:

Rule 807 (“Open Long Positions During Delivery Month”)

At such times and in such manner as shall be prescribed by the Manual, clearing members shall submit a complete and accurate record of dates of all open purchases for use in making deliveries. Clearing members shall be fully responsible for inventories submitted to the Clearing House. This rule shall not apply to trading in options contracts.

FINDINGS:

Pursuant to an offer of settlement in which BNP Paribas Securities Corp. (“BNP”) neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the CBOT Business Conduct Committee (“Panel”) found that it had jurisdiction over BNP pursuant to Rules 400 and 402, as BNP is a CBOT clearing member. The Panel also found that on July 6, 2012, BNP reported to the Exchange 128 long positions eligible for delivery in July 2012 Wheat Futures even though those positions had previously been closed out, and BNP was assigned to take physical delivery on 114 of the 128 positions. This inaccurate report represented 51.8% of the total intents in July 2012 Wheat on that day. After discovering its error, BNP retendered the 114 positions the following business day, July 9, 2012. The Panel concluded that BNP thereby violated CBOT Rule 807.

PENALTY:

In accordance with the settlement offer, the Panel ordered BNP to pay a fine of $25,000.

EFFECTIVE DATE:

October 13, 2014