NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 12-9175-BC

NON-MEMBER:

Typhon Capital Management, 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. Additionally, any person making a bid or offer that would, if accepted, cause such person to exceed the applicable position limits shall be in violation of this rule.

FINDINGS:

Pursuant to an offer of settlement in which Typhon Capital Management LLC (“Typhon”) neither admitted nor denied the rule violations upon which the penalty is based, on September 18, 2014, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that it had jurisdiction over Typhon pursuant to Rules 402 and 418, and that at the close of trading on December 10, 2012, accounts controlled by Typhon held positions in December 2012 Live Cattle Futures (“Dec 12 Cattle”) of 632 contracts long, which exceeded the spot month speculative position limit of 450 contracts in effect at that time by 182 contracts, or approximately 40.4%.

The Panel concluded that Typhon thereby violated CME Rule 562.

PENALTY:

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

EFFECTIVE DATE:

September 22, 2014