NOTICE OF DISCIPLINARY ACTION

FILE NO.:

NYMEX 13-9437-BC

MEMBER:

Ronin Capital LLC

EXCHANGE RULE:

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.

FINDINGS:

Pursuant to an offer of settlement Ronin Capital LLC (“Ronin”) presented at a hearing on February 20, 2014 in which Ronin, who is subject to the jurisdiction of the Exchange because at the time of the transaction at issue it was a NYMEX member, neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that on December 13, 2012, through a third-party broker, Ronin was a counterparty to an exchange of options for options (which is a type of EFRP transaction)that did not include documentation of the related OTC transaction and, therefore, was not bona fide EFRP transaction.

The Panel found that as a result, Ronin violated Rule 538.H.

PENALTY:

In accordance with the settlement offer, the Panel ordered Ronin to pay a fine to the Exchange in the amount of $10,000.

EFFECTIVE DATE:

February 24, 2014