NOTICE OF DISCIPLINARY ACTION

MEMBER FIRM:

Macquarie Equities Ltd

CME RULE VIOLATIONS:

538.H. Documentation (LEGACY)

Parties to any EFRP transaction must maintain all documents relevant to the Exchange contract and the cash, OTC swap, OTC option, or other OTC derivative, including all documents customarily generated in accordance with relevant market practices and any documents reflecting payment and transfer of title. Any such documents must be provided to the Exchange upon request, and it shall be the responsibility of the carrying clearing member firm to provide such requested documentation on a timely basis.

FINDINGS:

Pursuant to an offer of settlement in which Macquarie Equities Ltd (“MEL”) neither admitted nor denied the rule violation upon which the penalty is based, on December 15, 2015, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel or BCC”) found that it has jurisdiction over MEL pursuant to Rules 400 and 402 as the conduct occurred while MEL was an affiliate of Macquarie Futures USA LLC, a member of the Exchange, and that on December 12, 2013, MEL entered into a transitory EFRP transaction in CME foreign exchange (“FX”) products that did not contain documentation of the corresponding cash position and, thus, was not a bona fide EFRP transaction.

The Panel concluded that MEL thereby violated CME Rule 538.H.

PENALTY:

In accordance with the settlement offer, the Panel ordered MEL to pay a fine of $7,500.

EFFECTIVE DATE:

December 17, 2015