NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Cornerstone Futures, LLC

EXCHANGE RULE: Rule 526. – BLOCK TRADES

The Exchange shall designate the products in which block trades shall be permitted and determine the minimum quantity thresholds for such transactions. The following shall govern block trades:

F. The seller must ensure that each block trade is reported to the Exchange within five minutes of the time of execution. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.

FINDINGS:

Pursuant to an offer of settlement that Cornerstone Futures, LLC (“Cornerstone”) presented at a hearing on November 23, 2015, in which Cornerstone neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that Cornerstone, a non-member, is subject to the jurisdiction of the Exchange pursuant to NYMEX Rules 400 and 418. The Panel also found that during the time period from March 2014 through August 2015, Cornerstone executed numerous block trades for customers in various Exchange contracts that were not reported within the required time limit following execution and that Cornerstone failed to initially report accurate trade details for certain block trades to the Exchange.

The Panel found that as a result of the foregoing, Cornerstone violated NYMEX Rule 526.F (“Block Trades”)

PENALTY:

In accordance with the settlement offer, the Panel ordered Cornerstone to pay a fine to the Exchange in the amount of $50,000.