NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Pacific Investment Management Company LLC

CBOT RULE VIOLATIONS:

Rule 562 (“Position Limit Violations”) (in part)

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 in which Pacific Investment Management Company LLC (“PIMCO”) neither admitted or 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 PIMCO pursuant to rules 402 and 418. The Panel also found that on November 21, 2014, PIMCO held end of day net short positions in excess of the single month position limit in the January 2015 Soybean Meal contract by 44 contracts, or 0.676%, and in excess of the all months position limit by 375 contracts, or 5.769%. On November 24, 2014, PIMCO held end of day net short positions in excess of the single month position limit in the January 2015 Soybean Meal contract by 107 contracts, or 1.646%, and the all months position limit by 1,090 contracts, or 16.769%. On November 25, 2014, PIMCO liquidated its overage to bring its position into compliance with the single month and all contract months combined position limits, and did not profit from doing so. The Panel concluded that PIMCO thereby violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered PIMCO to pay a fine of $35,000.

EFFECTIVE DATE:

July 24, 2015