NOTICE OF DISCIPLINARY ACTION

FILE NO.:

COMEX 13-9621-BC

NON-MEMBER:

REPUBLIC METALS CORPORATION

EXCHANGE RULES:

538.H. Documentation

Parties to any EFRP transaction must maintain all documents relevant to the Exchange contract and the cash, OTC swap, OTC option, or other OTC derivatives, including all documents customarily generated in accordance with relevant market practices and any documents reflecting payment and transfer of title. Any such documents must be provided to the Exchange upon request, and it shall be the responsibility of the carrying clearing member firm to provide such requested documentation on a timely basis.

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 that Republic Metals Corporation (“Republic”) presented at a hearing on April 29, 2014 in which Republic neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“Panel”) found that Republic is subject to the jurisdiction of the Exchange pursuant to Rule 418 and that on numerous occasions between February and August 2013 Republic entered into EFRP transactions in which Republic was on both sides of the transactions. The transactions were done for the purpose of moving positions from one Republic account to another but were executed in a manner that resulted in improper wash trades. The Panel also found that the transactions did not contain documentation of the corresponding cash positions and, thus, were not bona fide EFRP transactions.

The Panel found that as a result of the foregoing, Republic violated Rules 534 and 538.H.

PENALTY:

In accordance with the settlement offer, the Panel ordered Republic to pay a fine to the Exchange in the amount of $85,000.

EFFECTIVE DATE:

May 1, 2014