NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 12-7432-BC

MEMBER FIRM:

NEWEDGE USA LLC

CBOT RULE VIOLATIONS:

536. RECORD KEEPING REQUIREMENTS FOR PIT, GLOBEX, AND NEGOTIATED TRADES

D. Customer Type Indicator (CTI) Codes (in part)

Each clearing member must identify each transaction executed on the trading floor or on the Globex platform on the record of transactions submitted to the Exchange with the correct customer type indicator (CTI) code.

FINDINGS:

Pursuant to an offer of settlement in which Newedge USA LLC (“Newedge”) neither admitted nor denied the rule violations upon which the penalty is based, on May 28, 2014, a Panel of the CBOT Business Conduct Committee (“Panel”) found that for the time periods of May 24, 2012, through June 6, 2012, and July 2, 2012, through July 16, 2012, Newedge submitted numerous instances of incorrect CTI codes.

The Panel concluded that Newedge violated CBOT Rule 536.D.

PENALTY:

In accordance with the settlement offer, the Panel fined Newedge $1500.

EFFECTIVE DATE:

May 30, 2014