NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 14-9838-BC

NON-MEMBER:

ELLIOTT MANAGEMENT CORPORATION

CBOT RULE VIOLATION:

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 Elliott Management Corporation (“Elliott”) presented at a hearing on October 28, 2014, in which Elliott neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the CBOT Business Conduct Committee (“BCC”) found that Elliott was subject to the jurisdiction of the BCC pursuant to CBOT Rule 418 and that at the close of business on May 8, 2014, Elliott held a futures equivalent position of 6,814.402 short Soybean Meal (“Soybean Meal”) futures contracts, which was 314.402 contracts, or 4.84%, in excess of the 6,500 standard all months limit. Prior to realizing it was over the limit, on trade date May 9, 2014, Elliott continued to increase its position and held a futures equivalent position of 6,853.402 short Soybean Meal futures contracts, which was 353.402 contracts, or 5.44%, over the 6,500 standard all months limit. After realizing it was over the limit, Elliott traded itself back into compliance, resulting in profits of $125,082.24.

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

PENALTY:

In accordance with the settlement offer, the Panel ordered Elliott to pay a fine to the Exchange in the amount of $20,000 and disgorge profits of $125,082.24.

EFFECTIVE DATE:

October 30, 2014