NOTICE OF DISCIPLINARY ACTION

FILE NO.:

COMEX 13-9628-BC

MEMBER:

KATAMAN METALS LLC

EXCHANGE RULE: EXCHANGE RULE 538. EXCHANGE FOR RELATED POSITIONS

The following transactions shall be permitted by arrangement between parties in accordance with the requirements of this rule: Exchange for Physical (“EFP”) – A privately negotiated and simultaneous exchange of an Exchange futures position for a corresponding cash position. Exchange for Risk (“EFR”) – A privately negotiated and simultaneous exchange of an Exchange futures position for a corresponding OTC swap or other OTC instrument. Exchange of Options for Options (“EOO”) – A privately negotiated and simultaneous exchange of an Exchange option position for a corresponding OTC option position or other OTC instrument with similar characteristics. For purposes of this rule, an EFP, EFR or EOO shall be referred to as an Exchange for Related Position (“EFRP”).

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.

FINDINGS:

Pursuant to an offer of settlement that Kataman Metals LLC (“Kataman”) presented at a hearing on November 25, 2014, in which Kataman neither admitted nor denied the factual allegations or rule violations upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“Panel”) found that found it had jurisdiction over Kataman pursuant to Exchange Rules 400 and 402 as the conduct occurred while Kataman was a COMEX member, and that on June 28, 2013, Kataman entered into an EFRP transaction which did not contain sufficient documentation of the related OTC transaction and was therefore not a bona fide EFRP transaction.

The Panel concluded that Kataman violated Exchange Rule 538.H. (“Exchange for Related Positions - Documentation”).

PENALTY:

In accordance with the settlement offer, the Panel ordered Kataman to pay a fine to the Exchange in the amount of $15,000.

EFFECTIVE DATE:

November 28, 2014