NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

MAREX SPECTRON ASIA PTE LTD.

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 Marex Spectron Asia Pte Ltd. (“Marex Spectron Asia”), presented at a hearing on February 18, 2015, in which Marex Spectron Asia 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 Marex Spectron Asia was subject to the jurisdiction of the BCC pursuant to Exchanges Rules 400 and 402 as an affiliate of a NYMEX member, and that on trade date January 3, 2014, Marex Spectron Asia executed an EFRP transaction that did not contain proper documentation and therefore was not a bona fide EFRP.

The Panel concluded that Marex Spectron Asia violated Legacy Exchange Rule 538.H.

PENALTY:

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