NOTICE OF DISCIPLINARY ACTION

FILE NO.:

NYMEX 13-9648-BC

NON-MEMBER:

BBSP PARTNERS EUROPE

NYMEX RULE VIOLATIONS:

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 524.A. TRADING AT SETTLEMENT (“TAS”) TRANSACTIONS

2. TAS orders may be entered on Globex at any time the applicable contracts are available for TAS trading on Globex and during each TAS contract’s prescribed pre-open time period. The initiation of any TAS order on Globex outside these time periods is prohibited.

FINDINGS:

Pursuant to an offer of settlement BBSP Partners Europe (“BBSP Partners”) presented at a hearing on October 28, 2014, in which BBSP Partners neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over BBSP Partners pursuant to Exchange Rules 400 and 418 as the conduct was transacted on CME Globex electronic trading platform, by a trader employed by BBSP Partners, and that on four business days between August 2013 and October 2014, the trader entered Trading at Settlement (TAS) orders prior to the security status message stating that the product group had entered a pre-open state. The Panel also found that BBSP Partners failed to diligently supervise its trader in a manner sufficient to ensure that the trader did not submit such TAS orders prior to the prescribed pre-open time period.

The Panel found that, as a result, BBSP Partners violated Exchange Rules 432.W (General Offenses – Failure to Supervise) and 524.A. (Trading at Settlement “TAS”).

PENALTY:

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

EFFECTIVE DATE:

October 30, 2014