NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Wellca International Trading Limited

EXCHANGE RULES: Rule 432. GENERAL OFFENSES

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

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 of 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 Wellca International Trading Limited (“Wellca”) presented at a hearing on December 16, 2015 in which Wellca neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“Panel”) found that Wellca is subject to the jurisdiction of the Exchange pursuant to Rules 400 and 418 and that on March 3, 2014, and March 7, 2014, two Wellca traders entered a series of wash trades in the May 2014 Copper Futures contract between accounts with the same beneficial owner. Wellca failed to diligently supervise its traders in a manner sufficient to ensure that they were familiar with Exchange rules.

The Panel found that as a result of the foregoing, Wellca violated Comex Rules 432.W and 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Wellca to pay a fine to the Exchange in the amount of $50,000.