NOTICE OF DISCIPLINARY ACTION

MEMBER:

JEFFERIES BACHE FINANCIAL SERVICES INC.

NYMEX RULE: 562. POSITION LIMIT VIOLATIONS

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement Jefferies Bache Financial Services Inc. (“Jefferies”) presented at a hearing on February 18, 2015, in which Jefferies neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over Jefferies as a COMEX member pursuant to Rules 400 and 402, and that on July 10, 2014, Jefferies exceeded the expiration month position limit in the July 2014 Copper Futures (“JUL14 Copper”) contract by holding an open futures equivalent position of 201 long JUL14 Copper contracts, 1 contract (0.50%) over the standard expiration month limit in effect for trade date July 10, 2014. The Panel also found that Jefferies exceeded position limits on an intraday basis on two occasions on July 11, 2014 by 18 JUL14 Copper contracts (9%) and 5 JUL14 Copper contracts (2.5%). Furthermore, the Panel found that Jefferies also exceeded position limits on an intraday basis on July 14, 2014 by 1 JUL14 Copper contract (.50%) and July 15, 2014 by 6 JUL14 Copper contracts (3%). For the JUL14 Copper contract, expiration month limits were effective as of the close of business on June 27, 2014 and remained in effect through July 29, 2014.

The Panel found that as a result, Jefferies violated Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Jefferies to pay a fine to the Exchange in the amount of $40,000.