NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

ICAP CORPORATES LLC

NYMEX RULES:

RULE 432. GENERAL OFFENSES (IN PART)

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.

RULE 526. BLOCK TRADES

The Exchange shall designate the products in which block trades shall be permitted and determine the minimum quantity thresholds for such transactions. The following shall govern block trades:

F. Unless otherwise agreed to by the principal counterparties to the block trade, the seller, or, in the case of a brokered transaction, the broker handling the block trade, must ensure that each block trade is reported to the Exchange within the time period and in the manner specified by the Exchange. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.

FINDINGS:

Pursuant to an offer of settlement that ICAP Corporates LLC (“ICAP Corp.”) presented at a hearing on December 10, 2020, in which ICAP Corp. neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that between April 2019 and December 2019 and April 2020 and June 2020, ICAP Corp. executed numerous block trades for customers in various NYMEX Energy futures contracts, consisting primarily of natural gas products, that ICAP Corp. failed to report to the Exchange within the required time period following execution, as well as failed to report accurate trade details for these block trades to the Exchange. The Panel also found that, during these time frames, ICAP Corp. failed to diligently supervise the execution of block trades by its employees to enable compliance with Exchange block trade reporting requirements.

The Panel concluded that ICAP Corp. violated Exchange Rules 432.W. (General Offenses – Failure to Supervise) and 526.F. (“Block Trades”).

PENALTY:

In accordance with the settlement offer, the Panel ordered ICAP Corp. to pay a fine to the Exchange in the amount of $100,000.