NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Vattenfall Energy Trading Gmbh

NYMEX RULE VIOLATION: 562. Position Limit Violations (in part)

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 in which Vattenfall Energy Trading GmbH (“Vattenfall”) neither admitted nor denied the rule violation upon which the penalty is based, on April 29, 2021, a Panel of the New York Mercantile Exchange Business Conduct Committee (“Panel”) found that at the close of business on January 14, 2021, Vattenfall held a 4,000-lot February 2021 WTI Crude Oil Futures (“FEB21 CL”) position, which was 33.3% over the 3,000 lot FEB21 CL position limit that went into effect at the close of business on January 14, 2021. Vattenfall realized a profit of $1,440.00 when it reduced the firm’s excess FEB21 CL futures position on January 15, 2021.

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

PENALTY:

In accordance with the settlement offer, the Panel ordered Vattenfall to pay a fine in the amount of $25,000 and disgorge profits in the amount of $1,440.00.