NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

XINDEN TRADING PTE LTD

NYMEX RULE VIOLATION: 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 Xinden Trading PTE LTD (“Xinden”) presented at a hearing on October 21, 2020 in which Xinden neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the Business Conduct Committee found that at the close of business on April 23, 2020, Xinden and its affiliate, Sino Treasure Metal Holding Ltd. (“Sino”) held an aggregated futures equivalent position of 1,810 long MAY20 Natural Gas contracts, which was 810 contracts (81%) over the standard position limit in effect for trade dates April 24, 27, and 28, 2020.

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

PENALTY:

In accordance with the settlement offer, the Panel ordered Xinden to pay, jointly and severally with Sino, a fine to the Exchange in the amount of $30,000.