Row Asset Management, Llc

Allegations: RULE 562. POSITION LIMIT VIOLATIONS A PANEL OF THE NYMEX BUSINESS CONDUCT COMMITTEE ("BCC") FOUND THAT AT THE CLOSE OF BUSINESS ON FEBRUARY 21, 2017, AS A RESULT OF THE DELTA ON ROW ASSET MANAGEMENT, LLC'S (THE "ADVISER") MARCH 2017 NATURAL GAS ("MAR17 NG") OPTIONS, THE ADVISER HELD A FUTURES EQUIVALENT POSITION OF 1,053 MAR17 NG CONTRACTS WHICH WAS 53 CONTRACTS (5.30%) OVER THE 1,000 LOT STANDARD EXPIRATION MONTH LIMIT IN MAR17 NG, IN EFFECT AS OF THE CLOSE OF BUSINESS THAT SAME DAY. ON FEBRUARY 22, 2017, AS A RESULT OF A CHANGE IN THE DELTA ON THE ADVISER'S MAR17 NG OPTIONS, THE ADVISER ACCRUED A FUTURES EQUIVALENT POSITION OF 1,181 MAR17 NG CONTRACTS, WHICH WAS 181 CONTRACTS (18.10%) OVER THE ABOVE-REFERENCED STANDARD EXPIRATION MONTH LIMIT. THE ADVISER SUBSEQUENTLY LIQUIDATED ITS OVERAGE POSITION, RESULTING IN PROFITS OF $52,700. THE PANEL FOUND THAT, AS A RESULT, THE ADVISER VIOLATED NYMEX RULE 562. Status: Final Sanction Detail: THE ADVISER AGREED TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $35,000 AND TO DISGORGE PROFITS IN THE AMOUNT OF $52,700. WIRE FOR PAYMENT WAS SENT ON JULY 25, 2017. Summary: PURSUANT TO AN OFFER OF SETTLEMENT ROW ASSET MANAGEMENT, LLC (THE "ADVISER") PRESENTED AT A HEARING ON JULY 20, 2017, IN WHICH THE ADVISER NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED. IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE ADVISER AGREED TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $35,000 AND TO DISGORGE PROFITS IN THE AMOUNT OF $52,700.