NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 13-9384-BC

NON-MEMBER:

Bank of Oklahoma NA

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 Bank of Oklahoma NA (“BOK”) neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the CME Business Conduct Committee (“Panel”) found that it had jurisdiction over BOK pursuant to rules 402 and 418. The Panel also found that on April 8, 2013, BOK carried positions in April 2013 Live Cattle Futures (“Apr13 Live Cattle”) of 511 contracts short, which exceeded the spot month position limit of 450 contracts in effect at that time by 61 contracts, or approximately 13.56%. On April 9, 2013, BOK carried positions in Apr13 Live Cattle of 476 contracts short, which also exceeded the spot month position limit of 450 contracts by 26 contracts, or approximately 5.78%. On April 10, 2013, BOK liquidated its overage to bring its position into compliance with the spot month position limit, and did not profit from doing so. The Panel concluded that BOK thereby violated CME Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered BOK to pay a fine of $22,500.

EFFECTIVE DATE:

October 27, 2014