NOTICE OF DISCIPLINARY ACTION

FILE NO.:

NYMEX 14-9713-BC

MEMBER:

STEPHEN P. SULLIVAN

NYMEX RULE VIOLATION: RULE 524.A. TRADING AT SETTLEMENT (“TAS”) TRANSACTIONS (IN PART)

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 Stephen Sullivan (“Sullivan”) presented at a hearing on September 17, 2014, in which Sullivan neither admitted nor denied the rule violation or the finding or conclusions herein upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over Sullivan pursuant to Exchange Rules 400 and 402 as the conduct occurred while Sullivan was a NYMEX member, and that during the time period between September 2013 and January 2014, Sullivan entered Trading at Settlement (TAS) orders prior to the pre-open period in violation of NYMEX Rule 524.A. (Trading at Settlement (“TAS”) Transactions).

The Panel found that, as a result, Stephen Sullivan violated NYMEX Rule 524.A. (Trading at Settlement (“TAS”)).

PENALTY:

In accordance with the settlement offer, the Panel ordered Stephen Sullivan to pay a fine to the Exchange in the amount of $25,000.

EFFECTIVE DATE:

September 19, 2014