• NOTICE OF DISCIPLINARY ACTION

      • #
      • NYMEX 16-0600-BC
      • Effective Date
      • 16 June 2017
    • MEMBER:

      ELDORADO TRADING GROUP LLC

      EXCHANGE RULES: 432. General Offenses

      It shall be an offense:

      B.2. to engage in conduct or proceedings inconsistent with just and equitable principles of trade;

      W. For any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

      576. Identification of Globex Terminal Operators

      Each Globex terminal operator shall be identified to the Exchange, in the manner prescribed by the Exchange, and shall be subject to Exchange rules. If user IDs are required to be registered with the Exchange, it is the duty of the clearing member to ensure that registration is current and accurate at all times. Each individual must use a unique user ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using a user ID other than the individual’s own unique user ID.

      FINDINGS:

      Pursuant to an offer of settlement Eldorado Trading Group LLC (“Eldorado”) presented at a hearing on June 14, 2017, in which Eldorado neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC Panel”) found that on multiple occasions in December 2016 and January 2017, despite Market Regulation’s instruction to immediately discontinue this practice, Eldorado’s traders continued to submit Trading at Settlement (“TAS”) orders in various products with knowingly incomplete values in the Sender Location I.D. (Tag 142) field of its order messages to assist in gaining a queue advantage upon the opening of the TAS markets. Once attaining its position in the queue, Eldorado then modified its order messages to correct the knowingly incomplete data in the Sender Location I.D. field. Eldorado failed to supervise its traders to ensure that this practice was immediately corrected. Additionally, Eldorado failed to ensure that the TAG 50 registration for its traders accessing the Globex system was current, accurate and unique to each individual using Globex in that its traders entered these TAS orders using a TAG 50 I.D. registered to a different user.

      The Panel found that as a result of the foregoing, Eldorado violated Rule 432.B.2., 432.W. and 576.

      PENALTY:

      In accordance with the settlement offer and considering the Summary Access Denial previously imposed against Eldorado, the BCC Panel ordered Eldorado to pay a $125,000 fine.