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      • NYMEX 15-0305-BC
      • Effective Date
      • 28 July 2017

      Marmara Deri Ltd. Sti.


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


      On August 9, 2016, a Panel of the New York Mercantile Exchange (“NYMEX”) Probable Cause Committee (“PCC”) charged non-member, Marmara Deri Ltd. Sti. (“Marmara”) with violating NYMEX Rule 562, based on allegations that on November 23, 2015, Marmara held a long position of 1,225 December 2015 Natural Gas Futures (“DEC15 NG”) contract contracts, 225 contracts (22.5%) above the standard expiration month position limit in DEC15 NG, in effect at the close of business on November 20, 2015.

      On November 23, 2016, a Hearing Panel Chair of the NYMEX Business Conduct Committee (“BCC”) entered an order finding that Marmara failed to answer the charge issued against it. In failing to answer the charge, the Hearing Panel Chair further ordered that Marmara was deemed to have admitted the charge issued and waived its right to a hearing on the merits of the charge.

      Pursuant to NYMEX Rule 407.C., a sanctions hearing was held before a Panel of the BCC (“Panel”) on December 19, 2016. The Panel found that Marmara had committed a violation of NYMEX Rule 562 and imposed sanctions on Marmara.

      Marmara appealed the Panel’s order and a hearing was held before an Appellate Panel on March 21, 2017. On June 26, 2017, the Appellate Panel affirmed the Panel’s decision that Marmara had violated NYMEX Rule 562, and ordered that Marmara pay a fine of $50,000 and disgorge $79,140 in profit obtained as a result of liquidating its position in excess of the applicable limit.


      In accordance with NYMEX Rule 411, the Appellate Panel ordered that Marmara pay a $50,000 fine and disgorge profits in the amount of $79,140.