NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

WILLOWBRIDGE ASSOCIATES INC.

EXCHANGE RULE: 562. POSITION LIMIT VIOLATIONS

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

FINDINGS:

Pursuant to an offer of settlement Willowbridge Associates Inc. (“Willowbridge”) presented at a hearing on January 29, 2019 in which Willowbridge neither admitted nor denied the factual allegations or the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that, on trade date June 25, 2018, Willowbridge held a long position of 1,314 contracts in July 2018 Henry Hub Natural Gas Futures (“JUL18 NG”), which was 314 contracts, or 31.4%, over the standard expiration month limit, which went into effect at the close of business on June 22, 2018 and remained in effect through June 27, 2018.

The Panel found that as a result, Willowbridge violated Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Willowbridge to pay a fine to the Exchange in the amount of $25,000.