NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

ECLIPSE INTERNATIONAL INC.

EXCHANGE RULE:

RULE 526. – BLOCK TRADES

The Exchange shall designate the products in which block trades shall be permitted and determine the minimum quantity thresholds for such transactions. The following shall govern block trades:

F. Unless otherwise agreed to by the principal counterparties to the block trade, the seller, or, in the case of a brokered transaction, the broker handling the block trade, must ensure that each block trade is reported to the Exchange within the time period and in the manner specified by the Exchange. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.

RULE 432. GENERAL OFFENSES (in part)

It shall be an offense:

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

CME GROUP MARKET REGULATION ADVISORY NOTICE RA1806-5:

Block Trade Submission Requirements to CME Clearing

Please note that the execution time of a block trade is the time that the parties agree to the trade. Market Participants must accurately report the execution time of the block trade. The reporting of inaccurate execution times may result in disciplinary action.

FINDINGS:

Pursuant to an offer of settlement that Eclipse International, Inc. (“Eclipse”) presented at a hearing on April 29, 2020, in which Eclipse neither admitted nor denied the findings, conclusions or any rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that during the time period of April 2019 through July 2019, Eclipse submitted multiple block trades to the Exchange with inaccurate execution times and also, on certain occasions, failed to report block trades to the Exchange within the required time period following execution. Additionally, the Panel found that Eclipse failed to properly advise and train its employees as to relevant Exchange rules and Market Regulation Advisory Notices (“MRANs”) in a manner sufficient to ensure compliance with the same.

The Panel found that as a result of the foregoing, Eclipse violated NYMEX Rules 526.F (“Block Trades”) and 432.W. (“General Offenses – Failure to Supervise”).

PENALTY:

In accordance with the settlement offer, the Panel ordered Eclipse to pay a fine to the Exchange in the amount of $60,000.