NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Bright Point Capital Pte. Ltd.

EXCHANGE RULES:

Rule 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.

Rule 536.E. Negotiated Trades

At the time of execution, every order received from a customer for execution pursuant to Rule 526 (“Block Trades”) and Rule 538 (“Exchange for Related Positions”) must be in the form of a written or electronic record and include an electronic timestamp reflecting the date and time such order was received, and must identify the specific account(s) for which the order was placed. Such record shall also include an electronic timestamp reflecting the date and time such order was modified, returned, confirmed or cancelled.

Rule 432. General Offenses:

It shall be an offense:

W. for a Member to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

FINDINGS:

Pursuant to an offer of settlement, in which Bright Point Capital Pte. Ltd. neither admitted nor denied the Rule violations or factual findings upon which the penalty is based, on May 15, 2024, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that on January 31, 2023, a Bright Point employee placed buy and sell orders in the same product and expiration month in the Methanol and NGL futures markets between two trading accounts with common beneficial ownership in order to transfer positions between the two accounts. The Bright Point employee knew or reasonably should have known that the purpose of the orders was to avoid taking a bona fide market position exposed to market risk.

Additionally, the Panel found that during this timeframe Bright Point failed to maintain complete written or electronic records for these wash block trades, including any electronic timestamp reflecting the date and time each order was received.

Finally, during this timeframe Bright Point failed to diligently supervise its employees with sufficient compliance training or educational materials regarding the reporting and execution of block trades and wash trades to ensure compliance with NYMEX rules regarding block trades and wash trades.

The Panel found that as a result of the foregoing, Bright Point violated NYMEX Rules 534, 536.E., and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Bright Point to pay a $75,000 fine.