NOTICE OF DISCIPLINARY ACTION

MEMBER:

ABN AMRO Clearing Chicago, LLC

RULE VIOLATION:

(Legacy) Rule 854. Concurrent Long and Short Positions (in part)

B. Concurrent long and short positions in physically delivered contracts subject to spot month position limits that are held by the same owner during the spot month must be offset by transactions executed in the market, by allowable privately negotiated transactions, or fulfilled through the normal delivery process, provided however that trades may be offset via netting, transfer or position adjustment to correct a bona fide clerical or operational error on the day the error is identified and the quantity of the offset does not represent more than one percent of the reported open interest in the affected futures contract month.

FINDINGS:

Pursuant to an offer of settlement in which ABN AMRO Clearing Chicago, LLC (“ABN AMRO”) neither admitted nor denied the rule violation upon which the penalty is based, on October 20, 2015, the BCC Panel found that for trade date June 28, 2013, ABN AMRO misreported the open interest positions in the July 2013 Lumber Futures contract for the customer origin. The Panel further found that on July 1, 2013, ABN AMRO submitted an adjustment to correct the error, but submitted that adjustment 16 minutes late. As a result, open interest in the July 2013 Lumber futures contract was overstate by 101 contracts, or 6.26%, during the spot month delivery expiration period.

The Panel found that, in committing these actions, ABN AMRO violated CME Rule 854.B.

PENALTY:

In accordance with the settlement offer, the Panel ordered ABN AMRO to pay a fine in the amount of $25,000.

EFFECTIVE DATE:

December 30, 2015