NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 12-9185-BC

MEMBER FIRM:

Jefferies Bache, 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 Jefferies Bache, LLC (“Jefferies Bache”) 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 found that during the time periods of July 25, 2012, through August 8, 2012, and April 1, 2013, through April 30, 2013, Jefferies Bache submitted incorrect CTI codes for numerous trades executed on the Exchange.

The Panel concluded that Jefferies Bache violated CBOT Rule 536.D.

PENALTY:

In accordance with the settlement offer, the Panel ordered Jefferies Bache to pay a fine of $2,000.

EFFECTIVE DATE:

May 30, 2014