NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

SOLAR APPLIED MATERIALS TECHNOLOGY CORP.

NYMEX RULE VIOLATIONS:

432.W. GENERAL OFFENSES (in part)

It shall be an offense for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

534 WASH TRADES PROHIBITED

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

FINDINGS:

Pursuant to an offer of settlement in which Solar Applied Materials Technology Corp. neither admitted nor denied the rule violations or factual allegations upon which the penalty is based, on March 2, 2022, a Panel of the New York Mercantile Business Conduct Committee (“Panel”) found that, on January 14, 2021, January 15, 2021, and January 19, 2021, a Solar Applied employee executed numerous wash trades in the April 2021 Platinum Futures market between accounts with common beneficial owner in order to move positions between trading accounts. The Panel also found that during this time frame Solar Applied failed to diligently supervise its employee by not providing sufficient compliance training or educational materials regarding NYMEX rules and failed to supervise his trading to ensure compliance with NYMEX rules regarding wash trades.

The Panel concluded that Solar Applied thereby violated NYMEX Rules 432.W. and 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Solar Applied to pay a fine in the amount of $40,000.