NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

EAGLE ENERGY BROKERS, 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 (IN PART)

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

CME GROUP RA2109-5

7. Block Trade Submission (in part)

The execution time of a block trade is the time that the trade is consummated, which is the time that the parties agree to the trade in principle. In that regard, spread block trades are deemed consummated at the time the parties agree to the differential or combination price, not the time the leg prices are determined. Market participants must accurately report the execution time of the block trade. The reporting of inaccurate execution times may result in disciplinary action.

FINDINGS:

Pursuant to an offer of settlement in which Eagle Energy Brokers, LLC neither admitted nor denied the Rule violations or factual findings upon which the penalty is based, on December 13, 2022, a Panel of the NYMEX Business Conduct Committee (“BCC Panel”) found that during the months of December 2021 and February 2022, Eagle Energy Brokers submitted block trades with inaccurate execution times for multiple block trades in various Crude Oil and Refined Products futures, options and spread contracts.

Eagle Energy Brokers also failed to properly advise and train its brokers as to relevant Exchange rules and Market Regulation Advisory Notices (“MRANs”) in a manner sufficient to ensure compliance with the Exchange’s block trade reporting rules.

The Panel found that as a result of the foregoing, Eagle Energy Brokers violated NYMEX Rules 526 and 432.W.

PENALTY:

In accordance with the settlement offer, the BCC Panel ordered Eagle Energy Brokers to pay a $40,000 fine.