NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

FOCUS AND VISION GENERAL TRADING LLC

EXCHANGE RULE: 432. General Offenses

It shall be an offense:

W. For any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

FINDINGS:

Pursuant to an offer of settlement Focus and Vision General Trading LLC (“Focus”) presented at a hearing on July 20, 2017, in which Focus neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“BCC Panel”) found that on multiple trade dates from January 2015 to June 2015, a trader employed by Focus engaged in a pattern of activity in which he entered multiple layered orders in the Gold futures contracts with the intent, at the time of order entry, to cancel the orders before execution. Specifically, the trader entered multiple layered orders to encourage market participants to trade opposite his smaller order resting on the opposite side of the market or to encourage other market participants to better his bid/offer in order to trade against those bettered bids or offers. After receiving a fill on the smaller order, the trader would cancel the layered orders he had entered on the opposite side of the book. Focus failed to properly supervise its trader to ensure that he conducted trading activities in compliance with Exchange rules.

The Panel found that as a result of the foregoing, Focus violated Rule 432.W.

PENALTY:

In accordance with the settlement offer, the BCC Panel ordered Focus to pay a fine of $30,000.