NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 16-0382-BC

NON-MEMBER FIRM:

AMP Capital Investors Limited

CBOT RULE VIOLATIONS:

538.C. Related Position

The related position component of an EFRP must be the cash commodity underlying the Exchange contract or a by-product, a related product or an OTC derivative instrument of such commodity that has a reasonable degree of price correlation to the commodity underlying the Exchange contract. The related position component of an EFRP may not be a futures contract or an option on a futures contract.

Each EFRP requires a bona fide transfer of ownership of the underlying asset between the parties or a bona fide, legally binding contract between the parties consistent with relevant market conventions for the particular related position transaction.

The execution of an EFRP transaction may not be contingent upon the execution of another EFRP or related position transaction between the parties where the transactions result in the offset of the related position without the incurrence of market risk that is material in the context of the related position transactions.

FINDINGS:

Pursuant to an offer of settlement in which AMP Capital Investors Limited (“AMP Capital”) neither admitted nor denied the rule violation upon which the penalty is based, on November 29, 2017, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on April 15, 2015, AMP Capital executed two EFRP transactions that were contingent upon each other, wherein each position was established and offset without the incurrence of material market risk. The Panel concluded that AMP Capital thereby violated CBOT Rule 538.C.

PENALTY:

In accordance with the settlement offer, the Panel ordered AMP Capital to pay a fine in the amount of $15,000.

EFFECTIVE DATE:

December 1, 2017