2014 Final Disciplinary Actions as of December 22, 2014 The following is a list of disciplinary actions that have resulted in the imposition of penalties for violations of specified provisions of the federal securities laws and/or the Constitution and Rules of the Exchange. New actions are added to the list as and when they are finalized. A.) Disciplinary Sanctions Imposed Pursuant to ISE Rule 1614, Imposition of Fines for Minor Rule Violations:  A member was fined $500 for not accurately reporting information to the Large Options Position Report (ISE Rule 415)  A member was fined $500 for not accurately reporting information to the Large Options Position Report (ISE Rule 415)  A member was fined $1,000 for exceeding the opening spread differentials (ISE Rule 803(b)(4)) B.) Disciplinary Sanctions Imposed Pursuant to ISE Rule 1603, Letters of Consent:  IMC Financial Markets was fined $2,500 for failing to meet its continuous quoting obligations due to a systemic issue during the second quarter of 2013 (ISE Rule 804(e)(2)(iii))  Jefferies & Company, Inc. was fined $30,000 for improperly hedging its anticipated facilitation of a customer order prior to disclosure of the customer order to the market place. (ISE Rule 400.02)  J.P. Morgan Securities, LLC was fined $145,000 for improperly hedging its anticipated facilitation of a customer order prior to disclosure of the customer order to the market place on four occasions and failing to correctly capture the time of receipt on three orders. (ISE Rule 400.02; 1400(a) and Section 17(a) of the Securities Exchange Act of 1934, and Rule 17a-3 promulgated thereunder)  Nomura Securities International, Inc. was fined $150,000 for improperly hedging its anticipated facilitation of a customer order prior to disclosure of the customer order to the market place on four occasions. (ISE Rule 400.02)  Barclays Capital Inc. was fined $30,000 for improperly hedging its anticipated facilitation of a customer order prior to disclosure of the customer order to the market place. (ISE Rule 400.02)  TJM Investments, LLC was fined $50,000 for designating orders as Qualified Contingent Cross (“QCC”) transactions on 6 occasions despite the fact that the stock and options components of each QCC transaction had not been executed at or near the same time and for failing to record the times at which the equity component of each QCC transaction was transmitted to the equity broker for execution. Additionally, the firm submitted options transaction using the QCC designation on 6 occasions despite the fact that there had been no corresponding stock component to the transaction. Furthermore, the firm did not have a supervisory system in place to ensure that its employees were in compliance with ISE rules when utilizing the QCC designation. The aforementioned conduct occurred between December 2011 and March 2012. (ISE Rules 401, 715(j) and Section 17(a) of the Securities Exchange Act of 1934, and rule 17a-3 promulgated thereunder)  Ronin Capital, LLC was fined $55,000. On August 28, 2012 and September 4, 2012, although the firm had developed a real-time automated system in response to the implementation of Rule 15c3-5 of the Exchange Act, a flaw in Ronin’s quoting logic resulted in its transmission of excessive quotes to the Exchange in two different options series. Additionally, on September 21, 2012, after its internal surveillance for monitoring quotes had been re-implemented with modified parameters, Ronin’s system detected excessive quoting by the firm in one options series, but the firm failed to turn off quoting with respect to that options series until approximately 30 minutes had elapsed, which resulted in the transmission of excessive quotes. (ISE Rule 401, Rule 15c3-5(b), (c)(1)(ii), and (c)(2)(i) of the Exchange Act)  optionsXpress, Inc. was fined $125,000. The firm failed to retain text messages sent or received by firm employees on firm-issued cellular devices and failed to retain complete billing records for firm-issued cellular devices used by firm employees for business purposes from May 2010 through April 2013. Additionally, the firm failed to maintain an adequate system of supervision designed to review the content of text messages sent or received by firm employees on firm-issued cellular devices and failed to have reasonable written supervisory procedures in place to supervise the content and retention of text messages sent or received by firm employees on firm-issued cellular devices at least from the period of 2007 through April 2013. (ISE Rule 401, 1400(a) and SEC Rule 17a4(b)(3)&(4))  Morgan Stanley & Co., LLC (“MSCO”) was fined $100,000. From the second quarter of 2012 through the second quarter of 2013, MSCO, as a PMM, effected options transactions at prices that were inferior to the National Best Bid or Offer (“NBBO”) on approximately 405 occasions in violation of ISE Rules 803(c)(2) and 1901. From the first quarter of 2012 through the second quarter of 2013, MSCO entered non-marketable limit orders on the ISE order book that locked or crossed the NBBO without taking appropriate corrective action in a timely manner on approximately 1,153 occasions in violation of ISE Rule 1902.  UBS Securities, LLC (“UBS”) was fined $65,000. During the period between January 2012 and July 2013, in 68 instances UBS traded at prices equal to the IBBO but improperly ahead of other ISE market participant orders that had priority, as a result of an inadvertent programming error that caused its proprietary system to inaccurately observe the ISE BBO prior to its utilization of the Trade Report function. Additionally, in 15 instances UBS traded at prices inferior to the IBBO and improperly ahead of other ISE market participant orders that had priority, as a result of the same programming error referenced in the paragraph above. This conduct constituted violations of ISE Rule 713(c) and (e). During the same time period, in 27 instances system issues at UBS caused orders that had been “locked” to the Firm to remain unexecuted for an extended period of time rather than immediately handling each order in violation of ISE Rule 803. UBS also failed to have adequate written supervisory procedures specific to the ISE’s Trade Report function, and failed to implement an adequate system of review to ensure compliance with ISE Rules 713 and 803 in violation of ISE Rule 401.  Raymond C. Forbes & Co., Inc. (“RAYF”) was fined $25,000. During the time period between August 2013 and April 2014, RAYF failed to respond to multiple regulatory requests in violation of ISE Rule 1400(b).  Merrill Lynch Professional Clearing Corp. (“Merrill Pro”) was fined $10,000. During the time period between April 2013 and June 2013 Merrill Pro, as a PMM, entered nonmarketable limit orders on the ISE order book that locked or crossed the National Best Bid or Offer without taking corrective action in a timely manner in violation of ISE Rule 1902. In addition, Merrill Pro failed to have sufficient supervisory controls in place, including sufficient written supervisory procedures, designed to prevent or detect situations where an order placed by the firm created a locked or crossed market condition in violation of ISE Rule 401.  Timber Hill LLC (“TMBR”) was fined $20,000. During the third quarter of 2012 through the fourth quarter of 2012, TMBR, as a PMM, traded through protected bids and offers in the marketplace in violation of ISE Rules 803(c)(2) and 1901.  Wolverine Execution Services, LLC (“WEXX”) was fined $235,000, of which $62,500 has been allocated to the ISE. WEXX will pay the balance of its fine to NASDAQ OMX BX, Inc., BOX Options Exchange LLC, NYSE Arca, Inc., The Nasdaq Options Market LLC, Nasdaq OMX PHLX, LLC, and NYSE MKT LLC pursuant to separate settlement agreements. Between July 1, 2011 and October 11, 2012, WEXX mismarked numerous options orders with inaccurate origin codes as a result of a programming error by the Firm in June 2011. As a result of the programming update error, certain orders coded B/D Customer had erroneously defaulted to either “customer” or “firm” origin codes. The foregoing mismarkings resulted in the execution of some transactions that may have been afforded priority to which they were not entitled and thereby potentially adversely impacted the execution and/or price of orders of other market participants. In addition, WEXX failed to have supervisory systems and controls in place, including a separate system of follow-up and review, reasonably designed to achieve compliance with the Exchange’s origin code requirements. The aforementioned conduct constituted separate and distinct violations of ISE Rules 400, 401, 712(a) and 1400(a), and Section 17(a) of the Exchange Act, as amended, and Rule 17a-3 promulgated thereunder.