NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

SINO TREASURE METAL HOLDING 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 Sino Treasure Metal Holding Ltd. (“Sino”) presented at a hearing on October 21, 2020, in which Sino 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, Sino and its affiliate, Xinden Trading PTE LTD (“Xinden”) 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, Sino violated Rule 562.

PENALTY:

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