NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 17-0687-BC

NON-MEMBER:

JML Capital, LLC

CME RULE VIOLATION:

Rule 562. Position Limit Violations (in part)

Any positions, including positions established intraday, in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement in which JML Capital, LLC (“JML”) neither admitted nor denied the rule violations upon which the penalty is based, on August 9, 2017, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that at the close of business on April 12, 2017, JML held a position of 422 contracts long in April 2017 Feeder Cattle Futures, which exceeded the spot month speculative position limit of 300 contracts by 122 contracts, or approximately 40.67%. On April 13, 2017, JML liquidated its overage to bring its position into compliance, and did not profit from doing so. The Panel concluded that JML thereby violated CME Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered JML to pay a fine of $25,000.

EFFECTIVE DATE:

August 11, 2017