• #
      • NYMEX 13-9656-BC-2
      • Effective Date
      • 21 August 2015
    • MEMBER:

      Blenheim Capital Management, LLC


      RULE 538.H. Documentation (Legacy)

      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.


      Pursuant to an offer of settlement Blenheim Capital Management, LLC (“Blenheim”) presented at a hearing on August 19, 2015, in which Blenheim neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found it had jurisdiction over Blenheim pursuant to NYMEX Rules 400 and 402 and that, on July 1, 2013, Blenheim entered into two EFRPs which did not contain documentation of the related OTC transaction and, therefore, were not bona fide EFRPs.

      The Panel found that, as a result, Blenheim violated Legacy Exchange Rule 538.H. (“Documentation”).


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