NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

ROBBINS FUTURES, INC.

EXCHANGE RULES:

NYMEX Rule 575 D. Disruptive Practices Prohibited

D. No person shall enter or cause to be entered an actionable or non-actionable message with intent to disrupt, or with reckless disregard for the adverse impact on, the orderly conduct of trading or the fair execution of transactions.

FINDINGS:

Pursuant to an offer of settlement Robbins Futures, Inc. (“Robbins Futures”) presented at a hearing on October 6, 2020, in which Robbins Futures 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 Robbins Futures provided a Leader/Follower subscription service (“Leader/Follower Program”) in which subscribers used an AutoTrade trading service to automatically mirror the live trading of a designated chosen “leader.” When a leader entered an order for his account, the order triggered a suspense account to execute a “blocked order,” which included the trades for both the leader and the followers, according to the followers’ pre-trade allocation instructions. The fills were averaged priced when allocated to the leader and the followers.

The Panel also found that on multiple dates during the time period of October 9, 2017 through February 23, 2018, a Tag50 User ID associated with the Robbins’ Leader/Follower Program, engaged in a pattern of entering multiple aggressive orders that traded through at 10 ticks and higher, resulting in significant price and volume movements in the October 2017 Platinum, January 2018 Platinum and April 2018 Platinum futures markets.

The Panel further found that Robbins’ Leader/Follower Program did not have protections in place to limit the size of blocked orders that could be entered into the market relative to market conditions and did not consider the current available liquidity in the relevant markets when entering the blocked orders, which resulted in the significant price and volume movement in those Platinum futures markets. As such, the orders entered as a result of Robbins’ Leader/Follower program were entered without regard for the adverse impact on the orderly conduct of trading or the fair execution of transactions.

The Panel found that as a result of the foregoing, Robbins Futures violated Rule 575.D.

PENALTY:

In accordance with the settlement offer, the BCC Panel ordered Robbins Futures to pay a fine of $30,000.