NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Mirabella Financial Services LLP

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 that Mirabella Financial Services LLP (“Mirabella”) presented at a hearing on March 16, 2021, in which Mirabella neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that on August 18, 2020 accounts owned or controlled by Mirabella, which were aggregated for the purposes of Exchange position limits, held September 2020 Light Sweet Crude Oil Futures (“SEP20 CL”) futures equivalent positions that exceeded the spot month position limit of 3,000 contracts in effect at that time. Specifically, Mirabella began trade date August 18, 2020 with a short position of 4,627 lots in SEP20 CL, 1,627 contracts (54.23%) over the standard expiration month position limit in effect for trade dates August 18, 19, and 20, 2020.

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

PENALTY:

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