NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Ginga Global Markets Pte Ltd

NYMEX RULE VIOLATIONS:

RULE 432. GENERAL OFFENSES

It shall be an offense:

B.2. to engage in conduct or proceedings inconsistent with just and equitable principles of trade.

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 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 Ginga Global Markets Pte Ltd (“Ginga”) presented at a hearing on November 23, 2015, in which Ginga neither admitted nor denied the findings or the rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over Ginga pursuant to Exchange Rules 400 and 418, and that on six dates between January 21, 2014 and June 5, 2014, Ginga brokered and arranged several transactions for the purpose of transferring $65,000 from one firm to another in order to correct an operational error made in a prior transaction.

The Panel also found that in two of the transactions, both executed as EFRPs, Ginga did not generate accurate broker confirmations in accordance with relevant market practices.

The Panel found that as a result of the foregoing, Ginga violated NYMEX Rule 432.B.2. and Legacy NYMEX Rule 538.H.

PENALTY:

In accordance with the settlement offer, the Panel ordered Ginga to pay a fine to the Exchange in the amount of $30,000.