NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 12-9146-BC

MEMBER:

CITIGROUP GLOBAL MARKETS, INC.

CBOT RULE VIOLATION:

811. POSITION CHANGE DATA

Position change data must be submitted to the Clearing House each trading day not later than the time specified by the Clearing House. Position change data will be in such form and contain such information as prescribed by the Clearing House. When requested, the identification of accounts will be made available to the Audit Department.

561. REPORTS OF LARGE POSITIONS (in part)

561.A. General Provisions

Clearing members, omnibus accounts and foreign brokers shall submit to the Exchange a daily report of all positions required to be reported as set forth in the Position Limit, Position Accountability and Reportable Level Table in the Interpretations Section at the end of Chapter 5. Positions at or above the reportable level in a particular expiration month of a futures contract or in all puts or in all calls of a particular option contract expiration month trigger reportable status. For a person in reportable status in a particular contract, all positions, regardless of size, in any futures contract month and in any put or call on that futures contract must be reported.

Additionally, the daily Large Trader submission to the Exchange must include for each reportable account 1) the EFRP volume bought and sold in the reportable instrument, by contract month, and for EOOs by put and call strike and 2) the number of delivery notices issued and the number of deliveries stopped in the reportable instrument.

Failure by an omnibus account or foreign broker to submit required information may result in a hearing by the Business Conduct Committee and result in limitations, conditions or denial of access of such omnibus account or foreign broker to any Exchange market. Notwithstanding the above, clearing members carrying such accounts remain responsible for obtaining and providing to the Exchange information regarding the ownership and control of positions in circumstances where an omnibus account or foreign broker has failed to provide the information to the Exchange.

FINDINGS:

Pursuant to an offer of settlement Citigroup Global Markets, Inc. (“Citigroup” or the “Firm”) presented at a hearing on May 28, 2014, in which Citigroup neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the CBOT Business Conduct Committee (“BCC”) found that it had jurisdiction over Citigroup pursuant to Exchange Rules 400 and 402 as the conduct occurred while Citigroup was a CBOT member, and that on trade date November 15, 2012, Citigroup reported several instances of inaccurate large trader positions for numerous CBOT contracts, in which it provided a corrected large trader file after the adjustment deadline of 9:00 a.m. CST, as well as reported five instances of inaccurate open interest position.

The Panel found that, as a result, Citigroup violated CBOT Rules 811 (Position Change Data) and 561 (Reports of Large Positions).

PENALTY:

In accordance with the settlement offer, the Panel ordered Citigroup Global Markets, Inc. to pay a fine to the Exchange in the amount of $4,500.

EFFECTIVE DATE:

May 30, 2014

Please see companion cases CME 12-9146-BC, NYMEX 12-9147-BC and COMEX 12-9147-BC.