NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 13-9547

MEMBER:

Daniel T. Zagorin

CBOT RULE VIOLATION[S]:

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.

13102.E. (“SOYBEAN MEAL FUTURES, POSITION LIMIT”) (in part)

In accordance with Rule 559., Position Limits and Exemptions, no person shall own or control positions in excess of:

2. 6,500 futures-equivalent contracts net long or net short in any single month other than the spot month or in all months combined.

FINDINGS:

Pursuant to an offer of settlement in which Daniel T. Zagorin (“Zagorin”) neither admitted nor denied the rule violation upon which the penalty is based, on July 1, 2014, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that it had jurisdiction over Zagorin pursuant to Rules 400 and 402 as the conduct occurred while Zagorin was an Exchange member, and on July 24, 2013, Zagorin held a position of 610 contracts long in August 13 Soybean Meal (“Meal”) futures and entered orders to sell 12,000 contracts of Meal futures. Had those offers been accepted, Zagorin would have had a total position of 11,390 contracts net short, which exceeds the 6,500 contract single month speculative position limit by 4,890 contracts or approximately 75%.

The Panel concluded that Zagorin thereby violated CBOT Rule 562 (Position Limit Violations).

PENALTY:

In accordance with the settlement offer, the Panel ordered Zagorin to pay a fine to the Exchange in the amount of $100,000 and have his access to all CME Group trading floors and direct access to all electronic trading and clearing platforms owned or controlled by CME Group suspended for a period of 30 business days, beginning on the effective date below and continuing for 30 business days from the date that the ordered fine is paid. The Panel considered Zagorin’s prior position limit violations in imposing this penalty.

EFFECTIVE DATE:

July 3, 2014