NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

PAUL ADAMS

EXCHANGE RULES:

RULE 524. TRADING AT SETTLEMENT (“TAS”) AND TRADING AT MARKER (“TAM”) TRANSACTIONS (in part):

The Exchange shall determine the products, contract months and time periods during which TAS and TAM transactions shall be permitted. Specific products, contract months and spreads eligible for pricing as TAS or TAM transactions are set forth in the TAS and TAM Table (“Table”) at the end of Chapter 5.

A. The following shall govern TAS transactions:

1. A TAS order may be entered on Globex at any time the applicable contract is available for TAS trading on Globex and during such TAS-eligible contract’s prescribed pre-open time period. The initiation of any TAS order on Globex outside these time periods is prohibited.

CME GROUP MARKET REGULATION ADVISORY NOTICE RA2116-5 (in part):

Market participants must have appropriate protocols in place to ensure that TAS orders are not initiated prior to receipt of the security status message.

FINDINGS:

Pursuant to an offer of settlement in which Paul Adams neither admitted nor denied the Rule violation or factual findings upon which the penalty is based, on March 15, 2023, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that on February 6, 2022, Adams entered a Trading at Settlement (TAS) order prior to the security status message stating that the product group had entered a pre-open state, and failed to have appropriate protocols in place to ensure that TAS orders were not initiated prior to receipt of the security status message.

The Panel found that as a result, Adams violated NYMEX Rules 524 and 524.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Adams to pay a fine to the Exchange in the amount of $10,000.