NOTICE OF DISCIPLINARY ACTION

MEMBER:

Raphael Kurlansik

EXCHANGE RULE:

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;

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the
dignity or good name of the Exchange;

T. it shall be an offense to engage in dishonorable or uncommercial conduct.

FINDINGS:

Pursuant to an offer of settlement that Raphael Kurlansik (“Kurlansik”) presented at a hearing on June 16, 2015, in which Kurlansik neither admitted nor denied the findings or the rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that Kurlansik is subject to the jurisdiction of the Exchange pursuant to Rules 402 and 418.

The Panel also found that on several trade dates in both June and July 2014, Kurlansik engaged in a pattern of activity in which he entered large manual orders in Heating Oil futures contracts without the intent to trade. Specifically, he entered these large orders to encourage market participants to trade opposite his smaller orders that were resting on the opposite side of the book. After receiving a fill on his resting smaller orders, Kurlansik would then cancel the large orders he had entered on the opposite side of the order book, within approximately one half of a second.

The Panel found that as a result of the foregoing, Kurlansik violated NYMEX Rules 432.B.2., 432.Q., and 432.T.

PENALTY:

In accordance with the settlement offer, the Panel ordered Kurlansik to pay a fine to the Exchange in the amount of $35,000 and suspended Kurlansik’s access to any CME Group trading floor, and direct or indirect access to any CME Group electronic trading or clearing platform for 10 business days, beginning on the effective date below. The suspension will run from June 18, 2015 through July 2, 2015.