NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Green Plains Asset Management LLC

CBOT RULE VIOLATION:

Rule 562. Position Limit Violations (in part)

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

FINDINGS:

Pursuant to an offer of settlement in which Green Plains Asset Management LLC (“GPAM”) neither admitted nor denied the rule violation upon which the penalty is based, on April 15, 2015, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that GPAM was subject to the BCC’s jurisdiction pursuant to Rules 402 and 418. The Panel further found that on trade date November 6, 2014, GPAM held an intraday position of 770 contracts short in November 2014 Soybean (“NOV14 Soybeans”) futures, which exceeded the spot month speculative position limit of 600 contracts by 170 contracts, or approximately 28.33%. Upon realizing it was over the limit, GPAM liquidated its overage to bring its position into compliance with the spot month speculative position limit, and did not profit from doing so. The Panel concluded that GPAM thereby violated CBOT Rule 562.

PENALTY:

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

EFFECTIVE DATE:

April 17, 2015