NOTICE OF DISCIPLINARY ACTION

MEMBER:

Totsa Total Oil Trading SA

NYMEX RULE VIOLATION: 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.

FINDINGS:

Pursuant to an offer of settlement that Totsa Total Oil Trading SA (“Totsa”) presented at a hearing on November 23, 2015, in which Totsa neither admitted nor denied the findings or the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over Totsa pursuant to Exchange Rules 400 and 402, and that on various dates between January 21, 2014 and June 5, 2014, Totsa executed six privately negotiated trades at fair and reasonable prices with a counterparty, for the purpose of ameliorating the impact of a prior error by the counterparty valued at $65,000. This conduct had the effect of transferring $65,000 from Totsa to the counterparty.

The Panel found that as a result of the foregoing, Totsa violated NYMEX Rule 432.B.2.

PENALTY:

In accordance with the settlement offer, the Panel ordered Totsa to pay a fine to the Exchange in the amount of $20,000.