Robert Jenkins Trading LLC
443. POSITION LIMIT VIOLATIONS
The Market Regulation Department and the BCC shall have the authority to enforce the position limit rules of the Exchange. For purposes of this rule, any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations. Additionally, any person making a bid or offer that would, if accepted, cause such person to exceed the applicable position limits shall be in violation of this rule.
Pursuant to an offer of settlement Robert Jenkins Trading LLC (“RJT”) presented at a hearing on December 20, 2011, in which RJT neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that RJT voluntarily submitted itself to the jurisdiction of the BCC for purposes of settling this matter, and that on June 24, 2010, a date subject to position limits for the expiring July 2010 Natural Gas Futures (“JUL10 NatGas”) contracts, RJT maintained a long JUL10 NatGas position in excess of the applicable speculative spot month position limit. On June 24, 2010, RJT purchased 1,813 JUL10 NatGas futures contracts, placing it 813 contracts (81.3%) over the applicable 1,000 contract spot month position limit. The following day, RJT traded out of this position. The purchase and sale of the 813 contracts above the applicable limits resulted in profits of $233,480.
The Panel found that as a result RJT violated Rule 443.
In accordance with the settlement offer, the Panel ordered RJT: (1) to pay a fine to the Exchange in the amount of $25,000 and (2) to disgorge profits in the amount of $233,480.
December 22, 2011
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