NOTICE OF DISCIPLINARY ACTION

MEMBER:

Schonfeld Strategic Management LLC

EXCHANGE RULES:

RULE 538.C. Related Position

The related position component of an EFRP must be the cash commodity underlying the Exchange contract or a by-product, a related product or an OTC derivative instrument of such commodity that has a reasonable degree of price correlation to the commodity underlying the Exchange contract. The related position component of an EFRP may not be a futures contract or an option on a futures contract.

Each EFRP requires a bona fide transfer of ownership of the underlying asset between the parties or a bona fide, legally binding contract between the parties consistent with relevant market conventions for the particular related position transaction.

The execution of an EFRP transaction may not be contingent upon the execution of another EFRP or related position transaction between the parties where the transactions result in the offset of the related position without the incurrence of market risk that is material in the context of the related position transactions.

The facilitation of the execution of an EFRP by any party that knows such EFRP is non bona fide shall constitute a violation of this Rule.

FINDINGS:

Pursuant to an offer of settlement in which Schonfeld Strategic Management LLC (“Schonfeld”) neither admitted nor denied the Rule violations or factual findings upon which the penalty is based, on June 4, 2024, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that on October 12, 2022, Schonfeld executed a non-bona fide EFRP transaction in the January 2023 Platinum Futures contract. The Panel found that the EFRP transaction was non-bona fide as it was contingent upon a simultaneous related position transaction and executed in a manner designed to avoid any material market risk associated with the EFRP’s related position components. Specifically, the Panel found that the EFRP transaction was negotiated simultaneously and in conjunction with a cash-market options straddle between Schonfeld and its counterparty. Schonfeld's clearing firm would not permit it to make or take delivery of the physical commodity underlying the EFRP, and the transactions were arranged to offset this component.

The Panel found that as a result of the foregoing, Schonfeld violated NYMEX Rule 538.C (Related Position).

PENALTY:

In accordance with the settlement offer, the Panel ordered Schonfeld to pay a fine to the Exchange in the amount of $20,000.