NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Wildhawk Energy, Inc.

EXCHANGE RULES:

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:

Rule 536. Recordkeeping Requirements For Globex And Negotiated Trades

H. Retention of Records

Each member and member firm and employees of the foregoing must keep full, complete and systematic records, including records created or transmitted electronically, together with all pertinent data and memoranda, of all transactions relating to its business of dealing in commodity interests and related cash or forward transactions in accordance with CFTC Regulation 1.35. Written and electronic records must be retained for a minimum of five years in permanent form. Oral communications required to be recorded pursuant to CFTC Regulation 1.35(a) must be retained for a minimum of one year past the date on which the oral communication occurred.

Rule 432. General Offenses

It shall be an offense:

W. for a Member to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

CME Group RA2201-5

Block Trade Submission (Section 7(c) 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. Market participants must accurately report the execution time of the block trade.

FINDINGS:

Pursuant to an offer of settlement, in which Wildhawk Energy, Inc. neither admitted or denied the Rule violations or factual findings upon which the penalty is based, on May 24, 2023, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that in March 2022, and May 2022, Wildhawk submitted multiple block trades in various Diesel and Gasoline futures spread contracts with inaccurate execution times, and failed to record and retain oral communications related to the execution of several block trade transactions. The Panel further found that Wildhawk 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, Wildhawk violated NYMEX Rules 526, 536.H. and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Wildhawk to pay a $45,000 fine.