NOTICE OF DISCIPLINARY ACTION

MEMBER:

Chopper Trading LLC  

CME 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 Chopper Trading LLC (“Chopper”) 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 Chopper pursuant to Rules 400 and 402 as the conduct occurred while Chopper was a CBOT member. The Panel also found that on June 30, 2014, while trading in the July 2014 Corn futures contract, Chopper exceeded the spot month speculative position limit of 600 contracts by 314 contracts, or approximately 52.33%. Chopper liquidated its overage to bring its positions into compliance within twelve minutes of the violation occurring. The Panel found that by exceeding the position limit on June 30, 2014, Chopper violated CBOT Rule 562.

PENALTY:

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

EFFECTIVE DATE:

July 20, 2015