NOTICE OF DISCIPLINARY ACTION

FILE NO.:

NYMEX 12-8899-BC

NON-MEMBER:

REVOLUTION CAPITAL MANAGEMENT

NYMEX RULE VIOLATION: 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 Revolution Capital Management (“Revolution”) presented at a hearing on July 24, 2014, in which Revolution neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that Revolution voluntarily submitted itself to the jurisdiction of the BCC for purposes of settling this matter and that on May 24, 2012, Revolution maintained an open futures equivalent position of 1,402 short June 2012 Henry Hub Natural Gas Futures contracts, which was 402 contracts (40.2%) over the standard expiration month limit which was in effect for trade dates May 24, 25, and 29, 2012. Furthermore, Market Regulation determined that Revolution realized a profit of $4,020 by reducing the firm’s excess Natural Gas Futures positions.

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

PENALTY:

In accordance with the settlement offer and taking into consideration Revolution’s financial condition when levying the sanction, the Panel ordered Revolution to pay a fine to the Exchange in the amount of $15,000 and disgorge profits in the amount of $4,020.

EFFECTIVE DATE:

July 28, 2014