MEMBER:

SUSQUEHANNA GOVERNMENT PRODUCTS, LLP

LEGACY 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 that Susquehanna Government Products, LLP (“Susquehanna”), presented at a hearing on April 15, 2015, in which Susquehanna neither admitted nor denied the factual allegations or rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that Susquehanna was a NYMEX member and therefore subject to the jurisdiction of the BCC pursuant to Exchanges Rules 400 and 402, and that on trade date June 2, 2014, Susquehanna entered into an EFRP transaction that did not contain documentation of the corresponding simultaneous swap transaction, and therefore was not a bona fide EFRP.

The Panel concluded that Susquehanna violated Legacy Exchange Rule 538.H.

PENALTY:

In accordance with the settlement offer, the Panel ordered Susquehanna to pay a fine to the Exchange in the amount of $7,500.