NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

BTG PACTUAL COMMODITIES (US) 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 BTG Pactual Commodities (US) LLC (“BTG”) presented at a hearing on December 16, 2015, in which BTG neither admitted nor denied the factual allegations or the NYMEX rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over BTG pursuant to Exchange Rules 402 and 418, and that at the opening of trading for trade date June 1, 2015, BTG held a futures equivalent position of 484 short June 2015 NYISO Zone G Peak LBMP Futures (“JUN15KG”) contracts, which was 54 contracts (12.56%) over the standard expiration month limit, which was then in effect. Within a very short time period of the overage on June 1, 2015, BTG liquidated its overage position, resulting in profits of $64,800.

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

PENALTY:

In accordance with the settlement offer, the Panel ordered BTG to pay a fine to the Exchange in the amount of $15,000 and disgorge profits in the amount of $64,800.