NOTICE OF DISCIPLINARY ACTION

FILE NO.:

NYMEX 13-9629-BC

NON-MEMBER:

Britannic Trading Ltd.

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 Britannic Trading Ltd. (“BT”) presented at a hearing on February 20, 2014 in which BT neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that on July 3, 2013, BT entered into two EFRP transactions which did not contain documentation of the related swap transaction and, therefore, were not bona fide EFRP transactions.

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

PENALTY:

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

EFFECTIVE DATE:

February 24, 2014