NOTICE OF DISCIPLINARY ACTION

MEMBER:

Aaron King

CBOT RULE VIOLATION:

Rule 432 (“General Offenses”) (in part)

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;

T. to engage in dishonorable or uncommercial conduct.

FINDINGS:

Pursuant to an offer of settlement in which Aaron King (“King”) neither admitted nor denied the rule violations upon which the penalty is based, on May 27, 2015, a Panel of the CBOT Business Conduct Committee found that it had jurisdiction over King pursuant to Rules 400 and 402 as the conduct occurred while King was a CBOT member, and that on one or more occasions between August 1, 2011, and November 23, 2011, King entered orders in various Agricultural contracts on the Globex electronic trading platform during the pre-opening period for the purpose of identifying the depth of the order book. The entry and cancelation of these orders caused fluctuations in the publicly displayed Indicative Opening Price (“IOP”). The Panel concluded that King thereby violated CBOT Rules 432.Q. and 432.T.

PENALTY:

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

EFFECTIVE DATE:

May 29, 2015