NOTICE OF DISCIPLINARY ACTION

MEMBER:

HTG CAPITAL PARTNERS, LLC

NYMEX RULE VIOLATION: 562. POSITION LIMIT VIOLATIONS

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement presented at a hearing on October 8, 2015, in which HTG Capital Partners, LLC (“HTG”) neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over HTG as a NYMEX member pursuant to Exchange Rules 400 and 402, and that on trade date May 28, 2015, HTG maintained open JUN15 HO futures equivalent commitments of 1,298 contracts long, which was 298 contracts, or 29.8%, over the standard 1,000 contract position limit in effect for trade dates May 27, May 28, and May 29, 2015. Market Regulation determined that HTG realized a gain of $1,264.70 by reducing the firm’s excess JUN15 HO position.

The Panel found that as a result, HTG violated Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered HTG to pay a fine to the Exchange in the amount of $25,000 and disgorge profits in the amount of $1,264.70.