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EXHIBIT L

RTX FINTECH & RESEARCH LLC (“RTX SEF”)

SWAP EXECUTION FACILITY APPLICATION FOR REGISTRATION COMPLIANCE WITH CORE PRINCIPLES1

SWAP EXECUTION 

FACILITY CORE

PRINCIPLE

ELEMENTS OF SWAP EXECUTION 

FACILITY CORE PRINCIPLE RTX SEF APPLICATION RELEVANT RTX SEF APPLICATION MATERIALS

Core Principle 1:

Compliance with Core 

Principles

(A) In general

To be registered, and maintain 

registration, as a swap execution 

facility, the swap execution facility 

shall comply with-

(i) all core principles described in 

Section 5h of the Act; and

(ii) any requirement that the 

Commission may impose by rule 

or regulation pursuant to Section 

8a(5) of the Act.

(B) Reasonable discretion of a swap 

execution facility

Unless otherwise determined by the 

Commission by rule or regulation, a 

swap execution facility described in 

paragraph (A) of this section shall 

have reasonable discretion in 

establishing the manner in which the 

swap execution facility complies with 

the core principles described in

Section 5h of the Act.

See generally RTX SEF’s Swap Execution Facility Application for 

Registration on Form SEF as submitted and, if applicable, amended and 

the Exhibits thereto (the “Application”).

All materials submitted with 

the Application.

1 References herein to a “Rule” refer to the applicable rule in the rulebook submitted as Exhibit M (the “Rulebook”). Terms used but not defined herein have the meanings 

assigned to them in the Rulebook.
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Core Principle 2: 

Compliance with Rules

A swap execution facility shall-

(A) establish and enforce compliance 

with any rule of the swap execution 

facility, including-

(i) the terms and conditions of the 

swaps traded or processed on or 

through the swap execution 

facility; and

(ii) any limitation on access to the 

swap execution facility;

(B) establish and enforce trading, trade 

processing, and participation rules 

that will deter abuses and have the 

capacity to detect, investigate, and 

enforce those rules, including means-

(i) to provide market participants 

with impartial access to the 

market; and

(ii) to capture information that may 

be used in establishing whether 

rule violations have occurred;

RTX SEF has established rules and procedures reasonably designed to 

ensure compliance with section 5h of the Commodity Exchange Act 

("CEA") and the rules of the Commodity Futures Trading Commission 

("CFTC"), including procedures to be used in entering and executing 

orders traded on RTX SEF. RTX SEF fulfills its compliance with the CEA, 

CFTC rules, and RTX SEF rules through oversight by its Regulatory 

Oversight Committee ("ROC"), Chief Compliance Officer ("CCO”), and 

Compliance Department.

The RTX SEF Compliance Department is under the supervision of the 

CCO. The CCO and the Compliance Department monitor RTX SEF's 

compliance with all regulatory, legal, and internal rules, policies, and 

procedures. The CCO is appointed by the RTX SEF Board. The CCO has 

available to him the resources to develop and enforce policies and 

procedures necessary to fulfill his duties as CCO and as required under 

CFTC regulations. The ROC oversees RTX SEF's regulatory program on 

behalf of the Board. The ROC has the authority, among other things, to 

(1) monitor the RTX SEF's regulatory program for sufficiency, 

effectiveness, and independence; and (2) oversee all facets of RTX SEF's 

regulatory program, including trade practice surveillance, market 

surveillance, and regulatory responsibilities with respect to members. 

The CCO is required to meet with the ROC at least quarterly.

The RTX SEF has contracted with the Surveillance Service Provider 

Eventus Systems, Inc. (“Eventus”) for the performance of market, trade 

practice, financial, and audit-trail surveillance. The RTX SEF, however, 

retains ultimate responsibility for the oversight of each Participant. The 

failure by any Person subject to the RTX SEF’s Rules to furnish any 

information requested by the Surveillance Service Provider that is 

related to the performance of its functions, as authorized by the RTX 

SEF and acting on behalf of the RTX SEF with respect to those functions, 

is a violation of RTX SEF’s Rules. The Compliance Department or 

regulatory service provider may review RTX SEF trades on a routine 

basis to determine whether suspicious activity relating to RTX SEF’s 

trading standards exists. Initially, on a post-trade basis, RTX SEF will 

monitor the market through the use of an automated trade surveillance 

system that will load and process daily orders and trades and other 

Rulebook (Exhibit M)

• Rule 203. Chief 

Compliance Officer

• Rule 204. Compliance 

Department

• Rule 205. Regulatory 

Oversight Committee

• Rule 206. Disciplinary 

Committee

• Rule 208. Emergency 

Powers

• Rule 307. Surveillance

• Rule 311. Termination of 

Participation

• Rule 401. Payment of 

Fees and Assessments

• Rule 402. Compliance 

with the Rules

• Rule 408. Cooperation 

with Investigations

• Rule 517. Real-Time 

Market Monitoring

• Part 9. Business Conduct

• Part 10. Disciplinary 

Proceedings

• Rule 1002. Investigations

• Rule 1011. Penalties

• Rule 1016. Action 

Against Non-Participants

Compliance Manual (Exhibit 

O)

• Generally

• Section VI. Trade

Practice and Market 

Surveillance
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events one day after the trading day has ended. The automated trade 

surveillance system is called “Validus,” and it is a product of Eventus.

Validus will assist Compliance Department staff in detecting possible 

trade practice violations by analyzing large data sets and investigating 

patterns of trading conduct. Validus can (a) compute, retain, and 

compare trading statistics, (b) analyze, monitor, and report on multiple 

market manipulation strategies, (c) reconstruct the sequence of market 

activity (d) perform market analysis (e) compute trade gains and losses 

and (f) support Compliance Department staff in performing in-depth 

analyses and ad hoc queries of trade related data. No later than 24 

hours after the trading day, Validus will analyze RTX SEF trade data and 

automatically generate alerts. (Exhibit O—the Compliance Manual—

includes an overview of Validus.)

The Compliance Department will be responsible for monitoring overall 

activity in each market on a real-time basis, as described in Rule 517 of 

the RTX SEF Rulebook. The Compliance Department will conduct realtime monitoring of trading on RTX SEF to detect disorderly trading, 

market anomalies and system anomalies. RTX SEF’s Compliance 

Department staff will perform real time market monitoring by using 

alerts generated by the RTX SEF trading system.

The Compliance Department, directly or indirectly through a regulatory 

service provider, will be primarily responsible for performing most of 

the investigatory work relating to trade practice and market surveillance 

inquiries and investigations.

The Compliance Department may conduct preliminary inquiries of 

potential irregularities. If the Compliance Department determines that 

there is no other reasonable explanation for the anomaly (i.e., system 

glitch) and further investigation is warranted, an “Investigative Report” 

will be completed and tracked by the Compliance Department. Every 

Participant, Clearing Participant, Authorized Trader, Customer, and 

Broker is required under the RTX SEF’s Rules to cooperate with any 

investigation of the RTX SEF, its designee, the Commission, the 

Department of Justice, or the NFA. And where the Compliance 

Agreements & Contracts 

(Exhibit N)

• Participant Agreement in

onboarding Form 101A

and Form 201A
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Department has reason to believe that any non-Participant is 

conducting his trading activities in violation of the Commodity Exchange 

Act, Commission Rules, or the RTX SEF Rules, it may require the nonParticipant and any Participant that handles or clears the nonParticipant’s trades to appear, produce documents, and testify at a 

Compliance Department interview or investigation, or at a hearing 

before the Disciplinary Committee.

The Compliance Department will also conduct inquiries and 

investigations related to real-time surveillance, trade practice, and 

market surveillance.

The Compliance Department’s investigations are governed by Part 10 of 

RTX SEF’s Rulebook. Part 10 also governs disciplinary proceedings, 

including the initiation and adjudication of proceedings. RTX SEF’s Board 

of Directors will appoint individuals to serve on a Disciplinary 

Committee.

RTX SEF has the ability to actively monitor trading activity and 

Participants in order to prevent market manipulation and has 

requirements to ensure that Participants maintain and make available 

information regarding their trading activity. The participation of any 

Person may be terminated at any time by the RTX SEF pursuant to Part 

10 of the Rules; or the participation of a Participant may be terminated 

if the RTX SEF determines, after reasonable notice and an opportunity 

to be heard, that such Participant no longer meets any one or more of 

the eligibility standards set forth in Rule 302. The RTX SEF may 

summarily suspend any Participant or Person exercising Trading 

Privileges or take other summary action against such a Person if the RTX 

SEF reasonably believes that such immediate action is necessary to 

protect the best interests of the marketplace. The RTX SEF may suspend

any Participant or impose other penalties pursuant to Part 10 for failure 

to pay any such fee, charge, or assessment on a timely basis.
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A swap execution facility shall-

(C) establish rules governing the 

operation of the facility, including

rules specifying trading procedures to 

be used in entering and executing 

orders traded or posted on the 

facility, including block trades; and

Parts 5, 6, and 7 of the Rulebook establishes rules governing the 

operation of the facility, including rules specifying trading procedures to 

be used in entering and executing orders traded or posted on the 

facility, including block trades.

Rulebook (Exhibit M)

• Part 5. Trading

• Part 6. Trading 

Electronically

• Part 7. Trading by Voice

A swap execution facility shall-

(D) provide by its rules that when a swap 

dealer or major swap participant 

enters into or facilitates a swap that 

is subject to the mandatory clearing 

requirement of section 2(h) of the 

CEA, the swap dealer or major swap 

participant shall be responsible for 

compliance with the mandatory

trading requirement under section 

2(h)(8) of the CEA.

Rule 501 provides that a Participant that is a Swap Dealer or Major 

Swap Participant that enters into or facilitates a Swap transaction on 

the RTX SEF that is subject to mandatory clearing pursuant to Section 

2(h) of the Commodity Exchange Act shall be responsible for compliance 

with the mandatory trading requirement under Section 2(h)(8) of the 

Commodity Exchange Act.

RTX SEF will specify Clearing Organizations to clear transactions effected 

on or subject to the Rules of the RTX SEF. Every Swap executed on or 

subject to the rules of the RTX SEF that is a Required Transaction will be 

forwarded by the RTX SEF to the Clearing Organization selected by the 

Participant directly to the Clearing Organization or via a straight-through 

processing facility.

Rulebook (Exhibit M)

• Rule 501. Required 

Transactions

• Rule 802. Relation to 

Clearing Organization

• Part 8. Clearing and 

Financial Integrity of 

Contracts

Core Principle 3:

Swaps Not Readily 

Susceptible to 

Manipulation

The swap execution facility shall permit 

trading only in swaps that are not readily 

susceptible to manipulation.

Part 5 of the RTX SEF Rulebook (entitled “Trading”) establishes rules 

regarding trading practices and SDR reporting such that only swaps that 

are not readily susceptible to manipulation are traded; Part 9 of the RTX 

SEF Rulebook (entitled “Business Conduct”) also sets forth conduct that 

is prohibited on the RTX. Further, RTX SEF has established Emergency 

Rules to maintain markets with fair and orderly trading and to prevent 

or address manipulation or disruptive trading practices.

Rulebook (Exhibit M)

• Rule 208. Emergency 

Powers

• Part 5. Trading

• Part 9. Business Conduct

• Part 13. Products

• 1303. Risk Controls for 

Trading

Core Principle 4: 

Monitoring of Trading 

and Trade Processing

The swap execution facility shall-

(A) establish and enforce rules or terms 

and conditions defining, or 

specifications detailing-

(i) trading procedures to be used in 

entering and executing orders 

traded on or through the 

Part 5 of the Rulebook establishes rules regarding (i) trading procedures 

to be used in entering and executing orders traded on or through the 

facilities of the swap execution facility; and (ii) procedures for trade 

processing of swaps on or through the facilities of the swap execution 

facility.

Under Rule 902, it is prohibited for any Participant or Customer to 

violate or fail to conform to the Rules and procedures of the RTX SEF or 

Rulebook (Exhibit M)

• Part 5. Trading

• Part 6. Trading 

Electronically

• Part 7. Trading by Voice

• Rule 902. Rule Violation

• Part 10. Disciplinary 

Proceedings
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facilities of the swap execution 

facility; and 

(ii) procedures for trade processing 

of swaps on or through the 

facilities of the swap execution 

facility; and

with any decision or order of a committee of the RTX SEF or any order of 

any officer, employee or agent of the RTX SEF when acting within his, 

her or its jurisdiction.

RTX SEF’s disciplinary procedures for violations of its rules are set forth 

in Part 10 of the Rulebook.

The swap execution facility shall-

(B) monitor trading in swaps to prevent 

manipulation, price distortion, and 

disruptions of the delivery or cash 

settlement process through 

surveillance, compliance, and 

disciplinary practices and procedures, 

including methods for conducting

real-time monitoring of trading and 

comprehensive and accurate trade 

reconstructions.

The Compliance Department conducts real-time monitoring of trading 

on RTX SEF for compliance purposes to prevent manipulation, price 

distortion, and disruptions of the settlement process.

RTX SEF will also maintain both a trade practice and market surveillance 

program to monitor for abuses, including manipulation; and RTX SEF has 

disciplinary procedures for violations of its rules. Such surveillance 

programs will utilize an automated trade surveillance system called 

“Validus,” which is a product of Events that is capable of detecting 

potential trade-practice violations. RTX SEF shall load and process 

orders and trades into Validus no later than 24 hours after completion 

of the trading day. Validus will assist Compliance Department staff in 

detecting possible trade practice violations by analyzing large data sets 

and investigating patterns of trading conduct. Validus can (a) compute, 

retain, and compare trading statistics, (b) analyze, monitor, and report 

on multiple market manipulation strategies, (c) reconstruct the 

sequence of market activity (d) perform market analysis (e) compute 

trade gains and losses and (f) support Compliance Department staff in 

performing in-depth analyses and ad hoc queries of trade related data. 

(Exhibit M—the Compliance Manual—includes an overview of Validus.)

Rulebook (Exhibit M)

• Rule 517. Real-Time 

Market Monitoring

• Part 10. Disciplinary 

Proceedings

Compliance Manual (Exhibit 

O)

• VI. Trade Practice and 

Market Surveillance

Core Principle 5: 

Ability to Obtain 

Information

The swap execution facility shall-

(A) establish and enforce rules that will 

allow the facility to obtain any 

necessary information to perform any 

of the functions described in this 

section;

Each Participant must make and file reports relating to the RTX SEF in 

accordance with (and in the manner and form and at such times as may 

be prescribed by) Commission Regulations. Moreover, each Participant, 

and, as applicable, Broker, must timely furnish the information relating 

to the RTX SEF as may from time to time be requested by any 

representative of the RTX SEF acting within the scope of the jurisdiction 

of the RTX SEF and in the course of its, his or her duties, except to the 

extent prohibited by Applicable Law. Any representative of the RTX SEF 

when engaged in the examination of any subject within the RTX SEF’s 

jurisdiction, has the power to summon and examine any Participant or 

Broker and any employee, officer, partner, or agent thereof in order to 

Rulebook (Exhibit M)

• Rule 403. Required 

Records and Reporting

• Rule 408. Cooperation in 

Investigations
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carry out the RTX SEF’s functions, except to the extent prohibited by 

Applicable Law. The representative of the RTX SEF may require such 

individual to submit a sworn statement of his or her information. From 

time-to-time, RTX SEF shall review each Participant’s and each Broker’s 

compliance with the applicable recordkeeping and audit trail 

requirements of the RTX SEF.

Each Participant, Clearing Participant, Authorized Trader, Customer, and 

Broker is also required to cooperate with any investigation of the RTX 

SEF, its designee, the Commission, Department of Justice, or the NFA.

The swap execution facility shall-

(B) provide the information to the 

Commission on request; and

RTX SEF shall provide the information to the Commission on request. Rulebook (Exhibit M)

• Rule 403. Required 

Records and Reporting

• Rule 408. Cooperation in 

Investigations

Compliance Manual (Exhibit 

O)

• Section IV. Regulatory 

and Legal Inquiries

The swap execution facility shall-

(C) have the capacity to carry out such 

international information-sharing 

agreements as the Commission may 

require.

As set forth in Rule 1203, RTX SEF may disclose certain confidential 

information to the Commission or to the United States Department of 

Justice pursuant to the requirements of the CEA, of any Commission 

regulation, or of any Governmental Agency with jurisdiction over the 

RTX SEF, which would allow the RTX SEF to carry out such informationsharing agreements and international information sharing-agreements 

as the CFTC may require.

Rulebook (Exhibit M)

• Rule 1203. 

Confidentiality of 

Information

Compliance Manual (Exhibit 

O)

• Section V.F. Privacy and 

Information Sharing

Core Principle 6:

Position Limits or 

Accountability

(A) In general

To reduce the potential threat of 

market manipulation or congestion, 

especially during trading in the 

delivery month, a swap execution 

facility that is a trading facility shall 

adopt for each of the contracts of the 

facility, as is necessary and 

To reduce the potential threat of market manipulation or congestion, 

especially during trading in the delivery month, RTX SEF may adopt for 

each of the contracts of the facility, as is necessary and appropriate, 

position limits or position accountability limits for speculators.

Rulebook (Exhibit M)

• Rule 1302. Position 

Limits or Position 

Accountability
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appropriate, position limitations or 

position accountability for

speculators.

(B) Position limits 

For any contract that is subject to a 

position limitation established by the 

Commission pursuant to section 6a(a) 

of the CEA, the swap execution 

facility shall-

(i) set its position limitation at a 

level no higher than the 

Commission limitation; and 

(ii) monitor positions established on 

or through the swap execution 

facility for compliance with the 

limit set by the Commission and 

the limit, if any, set by the swap 

execution facility.

To reduce the potential threat of market manipulation or congestion, 

the RTX SEF shall adopt for each of the contracts of the RTX SEF, as is 

deemed necessary and appropriate by the RTX SEF, position limits or 

position accountability levels for speculators. The RTX SEF shall on an 

on-going basis monitor positions established on or through the RTX SEF 

for unusual activity, including but not limited to, unusual volumes, 

patterns or concentrations of transactions.

Because RTX SEF initially will trade IRS and FX products, which are not 

subject to CFTC position limits, 17 C.F.R. Part 150, RTX SEF does not 

initially expect to establish position limits or position accountability 

limits for any contract.

Rulebook (Exhibit M)

• Rule 1302. Position 

Limits or Position 

Accountability

Compliance Manual (Exhibit 

O)

• Section VI.B.5. Position 

Limits or Position 

Accountability

Core Principle 7: 

Financial Integrity of 

Transactions

The swap execution facility shall establish 

and enforce rules and procedures for 

ensuring the financial integrity of swaps 

entered on or through the facilities of the 

swap execution facility, including the 

clearance and settlement of the swaps 

pursuant to section 2(h)(1) of the CEA.

RTX SEF has established various rules and procedures for ensuring the 

financial integrity of swaps entered on or through the facilities of the 

swap execution facility, including the clearance and settlement of the 

swaps pursuant to section 2(h)(1) of the CEA, as follows: 

Part 8 of the RTX SEF Rulebook (entitled “Clearing and Financial Integrity 

of Contracts”) requires all trades executed on RTX SEF to be routed 

through the Clearing Organization designated by each Participant at the 

time of order entry. Rule 803 of Part 8 establishes criteria for registering 

as a Clearing Participant.

Part 3 of the RTX SEF Rulebook establishes categories of participants 

and eligibility to be admitted as a participant on RTX SEF and criteria for 

becoming a participant.

Rulebook (Exhibit M)

• Part 8. Clearing and 

Financial Integrity of 

Contracts

• Rule 803. Clearing 

Authorization Required

• Part 3. Participants
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Core Principle 8: 

Emergency Authority

The swap execution facility shall adopt 

rules to provide for the exercise of 

emergency authority, in consultation or 

cooperation with the Commission, as is 

necessary and appropriate, including the 

authority to liquidate or transfer open 

positions in any swap or to suspend or 

curtail trading in a swap.

RTX SEF Rules set forth clear procedures and guidelines for decisionmaking regarding emergency intervention in the market, including 

procedures and guidelines to avoid conflicts of interests while carrying 

out such decision-making.

The measures available to RTX SEF in the case of an emergency include 

the ability to place into immediate effect temporary rules, order the 

liquidation of contracts, order the fixing of the settlement price or 

liquidation-only trading, suspending or limiting trading, modifying 

trading hours, imposition of position or price limits, and requiring 

Participants to meet special margin requirements.

Although the RTX SEF Rules authorize the liquidation or transfer of open 

positions in an emergency, RTX SEF notes that it does not expect any 

open positions to exist on the facility, nor does it anticipate than any of 

its Participants will post margin on or through RTX SEF.

Rulebook (Exhibit M)

• Rule 208. Emergency 

Powers

• Rule 209. Conflicts of 

Interest

Core Principle 9: 

Timely Publication of 

Trading Information

(A) In general

The swap execution facility shall 

make public timely information on 

price, trading volume, and other 

trading data on swaps to the extent 

prescribed by the Commission.

In accordance with Commission Rule 16.01, RTX SEF will record market 

data on swaps for each business day and publish it on its website.

RTX SEF will publish daily settlement prices to its website before 7 p.m. 

each business day.

Rulebook (Exhibit M)

• Rule 807. Establishment 

of Daily and Final 

Settlement Prices

• Rule 1207. Publication of 

Information

(B) Capacity of swap execution facility

The swap execution facility shall be 

required to have the capacity to 

electronically capture and transmit 

trade information with respect to

transactions executed on the facility.

As shown in Exhibit V (Technology Questionnaire), the platform has the 

capacity to electronically capture trade information executed on the 

facility. Trade information is stored electronically and includes the timeof-order entry, the time-of-trade execution, primary economic terms, 

and identifying data.

Specific processes are in place to recreate the life cycle of the order or 

trade, from an “active” database and a parallel “passive” database. 

Backups are stored in the primary backup location, as are all log files. 

Strong policies and procedures are in place to ensure data is captured 

and maintained electronically for audit purposes.

Technology Questionnaire 

(Exhibit V)

• Section 6 - System 

Operations 

• Section 7 - System 

Development 

• Section 3 - Information 

Security 

• Section 8 -Physical 

Security and 

Environmental Controls 
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Core Principle 10: 

Recordkeeping and 

Reporting

(A) In general

A swap execution facility shall-

(i) maintain records of all activities 

relating to the business of the 

facility, including a complete 

audit trail, in a form and manner 

acceptable to the Commission 

for a period of 5 years; 

(ii) report to the Commission, in a 

form and manner acceptable to 

the Commission, such 

information as the Commission 

determines to be necessary or 

appropriate for the Commission 

to perform the duties of the 

Commission under this chapter; 

and 

(iii) shall keep any such records 

relating to swaps defined in 

section 1a(47)(A)(v) of the CEA 

open to inspection and 

examination by the Securities 

and Exchange Commission.

RTX SEF will maintain records of all activities relating to the business of 

the facility, including a complete audit trail for all swaps executed on or 

subject to the RTX SEF Rules, investigatory files, and disciplinary files in 

accordance with the requirements of Commission Regulation 1.31 for a 

period of at least 7 years. RTX SEF will report to the CFTC in a form and 

manner acceptable to the CFTC as it determines necessary or 

appropriate for it to perform its regulatory responsibilities.

RTX SEF will also keep all records relating to swaps open to inspection 

and examination by the CFTC and Securities and Exchange Commission.

Each Participant shall also make and file reports relating to the RTX SEF 

in accordance with (and in the manner and form and at such times as 

may be prescribed by) Commission Regulations. Each Participant or 

Customer shall keep all records relating to the RTX SEF that are required 

by the Commission and Applicable Law to be kept, in such form and 

manner and for such period, as required by Commission Rule and 

Applicable Law, including but not limited to records by a Participant or 

Customer of its trading, including records of its activity in the index or 

instrument used as a reference price, the underlying commodity, and 

related derivatives markets, and make such records available, upon 

request, to the RTX SEF or, if applicable, and the Commission. Under 

Rule 1014, the Compliance Department may summarily impose a fine 

against any Participant or Customer who fails to keep any records 

required under any provision of the RTX SEF Rules.

Rulebook (Exhibit M)

• Rule 203. Chief 

Compliance Officer

• Rule 204. Compliance 

Department

• Rule 207. Restrictions on 

Directors, Officers, 

Committee Members, 

Employees and 

Consultants

• Rule 308. Recording of 

Conversations

• Rule 403. Required 

Records and Reporting

• Rule 407. User IDs and 

Confidentiality

• Rule 502. Permitted 

Transactions

• Rule 510. Block Trade 

Transactions

• Rule 512. Off-Facility 

Transactions

• Rule 513. Package 

Transactions

• Rule 514. Trade 

Cancellations and Price 

Adjustments

• Rule 607. Assisted Order 

Entry

• Rule 703. Voice Trading 

Systems

• Rule 706. Record 

Keeping and Reporting

• Rule 1009. Hearings

• Rule 1002. Investigations

• Rule 1014. Minor 

Penalties
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• Rule 1210. Audit Trail

Compliance Manual (Exhibit 

O)

• Section X.B. Record 

Retention Policy

(B) Requirements

The Commission shall adopt data 

collection and reporting 

requirements for swap execution 

facilities that are comparable to 

corresponding requirements for 

derivatives clearing organizations and 

swap data repositories.

RTX SEF’s company policies (Compliance Manual Section X.B.) and its

rules (Rules 203, 204, 207, 308, 403, 407, 502, 510, 512, 513, 514, 607, 

703, 706, 1009, 1002, 1014, and 1210) satisfy the recordkeeping 

requirements set forth in Commission Regulations 37.1001–1003 and 

the requirements imposed on SEFs in Commission Regulations Parts 43 

and 45.

Rulebook (Exhibit M)

• Rule 203. Chief 

Compliance Officer

• Rule 204. Compliance 

Department

• Rule 207. Restrictions on 

Directors, Officers, 

Committee Members, 

Employees and 

Consultants

• Rule 308. Recording of 

Conversations

• Rule 403. Required 

Records and Reporting

• Rule 407. User IDs and 

Confidentiality

• Rule 502. Permitted 

Transactions

• Rule 510. Block Trade 

Transactions

• Rule 512. Off-Facility 

Transactions

• Rule 513. Package 

Transactions

• Rule 514. Trade 

Cancellations and Price 

Adjustments

• Rule 607. Assisted Order 

Entry

• Rule 703. Voice Trading 

Systems
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• Rule 706. Record 

Keeping and Reporting

• Rule 1009. Hearings

• Rule 1002. Investigations

• Rule 1014. Minor 

Penalties

• Rule 1210. Audit Trail

Compliance Manual (Exhibit 

O)

• Section X.B. Record 

Retention Policy

Technology Questionnaire 

(Exhibit V)

• Generally

Core Principle 11: 

Antitrust Considerations

Unless necessary or appropriate to 

achieve the purposes of this chapter, the 

swap execution facility shall not-

(A) adopt any rules or take any actions 

that result in any unreasonable 

restraint of trade; or 

(B) impose any material anticompetitive 

burden on trading or clearing.

RTX SEF believes that its Rules and business plan have been designed to 

avoid unreasonable restraints of trade or the imposition of any material 

anticompetitive burden on trading. In particular, access to RTX SEF will 

not require the acquisition of any equity interest but will be available to 

a broad range and potentially unlimited number of Participants on a 

fair, equitable and timely basis.

Rulebook (Exhibit M)

• Rule 203. Chief 

Compliance Officer

• Rule 204. Compliance 

Department

• Rule 205. Regulatory 

Oversight Committee

• Rule 302. Eligibility

• Rule 303. Application 

Procedures

Compliance Manual (Exhibit 

O)

• Section V.G. (Antitrust 

Policy)

Core Principle 12: 

Conflicts of Interest

The swap execution facility shall-

(A) establish and enforce rules to 

minimize conflicts of interest in its 

decision-making process; and 

(B) establish a process for resolving the 

The RTX SEF Rules minimize conflicts of interest in decision-making 

processes and contain methods to ascertain the presence of conflicts of 

interest and to make decisions in the event of such a conflict. 

Rule 207 provides that no person shall vote or participate in 

deliberations on any Significant Action as a member of the Board of 

Rulebook (Exhibit M)

• Rule 205. Regulatory 

Oversight Committee

• Rule 206. Disciplinary 

Committee

• Rule 207. Restrictions on 
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conflicts of interest. Directors of the RTX SEF or any committee of the RTX SEF if such 

member knowingly has a material conflict of interest, including but not 

limited to having a direct and substantial financial interest in the result 

of the vote based upon positions maintained at the RTX SEF or 

elsewhere that could reasonably be expected to be affected by the 

action, subject to certain exceptions.

Additionally, Rule 207 provides limitations on the use or disclosure of 

material non-public information obtained through the performance of 

duties by (1) directors, committee members, officers, or employees of 

the RTX SEF; (2) directors, officers, or employees of any corporate 

affiliate of the RTX SEF performing functions for the RTX SEF; and (3) 

consultants of the RTX SEF.

The RTX SEF Compliance Manual prohibits RTX SEF employees from (i) 

trading, directly or indirectly, in any commodity interest traded on RTX 

SEF; (ii) trading, directly or indirectly, in any related commodity interest; 

(iii) trading, directly or indirectly, in a commodity interest traded on 

other SEFs or any designated contract market, or cleared by a 

derivatives clearing organization if the person has access to material, 

non-public information concerning such commodity interest; and (iv) 

trading, directly or indirectly, in a commodity interest traded on or 

cleared by a linked exchange if the person has access to material, nonpublic information concerning such commodity interest. With the Chief 

Compliance Officer’s prior written approval, however, personnel may 

participate in a pooled investment vehicle or other investment vehicle 

whose investments are directed by a third- party advisor if the member 

of the personnel has no direct or indirect control over transactions 

executed by the investment vehicles.

Additionally, RTX SEF and RTX SEF employees may not use for business 

or marketing purposes any proprietary data or personal information 

collected or received by RTX SEF, from or on behalf of any person, for 

the purpose of fulfilling that person’s regulatory obligations. However, 

RTX SEF and RTX SEF employees may share such information with one 

or more registered SEFs or DCMs for regulatory purposes.

Directors, Officers, 

Committee Members, 

Employees and 

Consultants

• Rule 209. Conflicts of 

Interest 

Compliance Manual (Exhibit 

O)

• Section V. Code of 

Business Conduct and 

Ethics
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In the absence of a final Commission regulation defining “public 

directors” for SEFs, the composition of RTX SEF’s Board and its 

committees will comply with the requirements the Commission has set 

forth in 17 C.F.R. Sec. 38.800 and in Appendix B to 17 C.F.R. Part 38.

RTX will have a Regulatory Oversight Committee that is composed of 

three Public Directors. The Regulatory Oversight Committee will oversee 

all aspects of RTX SEF's regulatory program on behalf of the Board. The 

Board will delegate sufficient authority, dedicate sufficient resources, 

and allow sufficient time for the Regulatory Oversight Committee to 

fulfill its mandate. It will make such recommendations to the Board as 

will, in its judgment, best promote the interests of RTX SEF. The 

Regulatory Oversight Committee will also have such other powers and 

perform such other duties as set forth in the RTX SEF Rules and as the 

Board may delegate to it from time to time. The ROC will assist the SEF 

in minimizing actual and potential conflicts of interest.

The SEF also maintains a Disciplinary Committee. The Disciplinary 

Committee is a committee of the RTX SEF whose members shall consist 

of such members appointed by the Board of Directors of the RTX SEF. 

The members of the Disciplinary Committee shall constitute the RTX 

SEF’s Review Panel(s) and Hearing Panel(s), which are disciplinary panels 

of the RTX SEF. A member of a Hearing Panel may not serve as a 

member of the Review Panel in the same matter and each Hearing 

Panel and each Review Panel must include a member that is not a 

Participant of the RTX SEF.

At least one member of the Disciplinary Committee, who shall be chair, 

must be a Public Participant, a person that would not be disqualified 

from serving as a Public Director under Commission Rule 1.3(ccc)(3). 

The Disciplinary Committee may include as members RTX SEF officers 

and employees. However, no employee of the Compliance Department 

of the RTX SEF may serve on the Disciplinary Committee.

The Disciplinary Committee is authorized to determine whether 

violations of the RTX SEF Rules have been committed, to accept offers of 

settlement, to set and impose appropriate penalties, and to exercise 
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such other powers and duties as provided in Part 10 of the RTX SEF 

Rules governing disciplinary proceedings.

Core Principle 13: 

Financial Resources

(A) In general 

The swap execution facility shall have 

adequate financial, operational, and 

managerial resources to discharge 

each responsibility of the swap 

execution facility. 

(B) Determination of resource adequacy

The financial resources of a swap 

execution facility shall be considered 

to be adequate if the value of the 

financial resources exceeds the total 

amount that would enable the swap 

execution facility to cover the 

operating costs of the swap 

execution facility for a 1-year period, 

as calculated on a rolling basis.

RTX SEF will maintain financial resources that exceed the total amount 

that would enable it to cover its operating costs for a one-year period, 

as calculated on a rolling basis.

RTX SEF’s Chief Operating Officer or an accounting officer designated by 

him or her will monitor RTX SEF’s compliance with the minimum 

financial requirements set forth in CFTC Regulations 37.1300-37.1306 at 

all times and advise the Board of Directors and the CCO if RTX SEF’s 

minimum capital requirement changes for any reason. For the purpose 

of the SEF, RTX SEF’s minimum requirement will at least be equal to a 

total amount that would enable RTX SEF to cover its operating costs for 

a period of at least one year, calculated on a rolling basis. Such financial 

resources will include unencumbered, liquid financial assets (i.e., cash 

and/or highly liquid securities) equal to at least six months’ operating 

costs.

RTX SEF’s Chief Operating Officer or an accounting officer designated by 

him or her will be responsible for the following:

• Ensuring that RTX SEF is in compliance with the minimum capital 

requirement;

• Establishing, maintaining and verifying that all accruals are posted 

properly and in compliance with generally accepted accounting 

principles;

• Reviewing all bank reconciliations on a monthly basis and ensuring 

that all un- reconciled material items are properly accounted for;

• Making certain that all books and records are properly prepared 

and posted on a current basis;

• Reconciling bank balances on a timely basis and posting all 

necessary adjustments to appropriate records; and

• Ensuring that relevant sub-ledger balances agree with general 

ledger balances.

Rulebook (Exhibit M)

• Rule 203

Compliance Manual (Exhibit 

O)

• Section IX.D. Compliance 

with Financial 

Requirements for SEFs

• Section IX.E. Early 

Warning Notification

Financials (Exhibit I)
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If RTX SEF’s minimum capital declines below the minimum amount 

required, RTX SEF will give notice of the deficiency that same day to the 

CFTC. The notice will specify RTX SEF’s minimum capital requirement 

and its current amount of capital.

In overseeing and reviewing RTX SEF’s compliance with Section 5h of 

the CEA, the CCO will monitor whether RTX SEF has adequate financial, 

operational, and managerial resources to discharge each responsibility 

of the SEF in accordance with Core Principle 13 and make the 

appropriate disclosures in the CCO’s annual compliance report.

Exhibit I includes a balance sheet, statement of income and expenses, 

statement of cash flows, and a statement of sources and application of 

revenues and all notes or schedules thereto, as of the most recent fiscal 

year, for the parent of RTX SEF, RTX Capital Markets, LLC, as well as a 

narrative of how the value of the financial resources held by RTX SEF is 

at least equal to a total amount that would enable it to cover its 

operating costs for a period of at least one year, calculated on a rolling 

basis, and a description of unencumbered, liquid financial assets (i.e. 

cash and/or highly liquid securities) equal to at least six months’ 

operating costs.

Core Principle 14: 

System Safeguards

The swap execution facility shall-

(A) establish and maintain a program of 

risk analysis and oversight to identify 

and minimize sources of operational 

risk, through the development of

appropriate controls and procedures, 

and automated systems, that-

(i) are reliable and secure; and 

(ii) have adequate scalable capacity; 

(B) establish and maintain emergency 

procedures, backup facilities, and a 

plan for disaster recovery that allow 

for-

(i) the timely recovery and 

resumption of operations; and 

Materials submitted with the Technology Questionnaire explain the 

controls to be used to ensure the proper function, adequate security, 

and capacity of automated trading systems and related systems such as 

those used for dissemination of market data and recording and safe 

storage of audit trail information. These controls include periodic, 

objective testing and review of automated systems to ensure that these 

systems are reliable, secure and have adequate scalable capacity. 

Results of such testing are retained as described with respect to Core 

Principle 10 (Recordkeeping and Reporting). Compliance with these 

policies is under the supervision of the Chief Compliance Officer.

Moreover, under Rule 208 (“Emergency Powers”), RTX SEF can exercise 

“Emergency Powers” in an “Emergency.” Subject to applicable law and 

the procedures of Rule 208, such powers are substantial and may 

require or authorize RTX SEF, the Board, any committee of the Board, 

the Chief Executive Officer, or any other Officer to take actions 

Rulebook (Exhibit M)

• Rule 208. Emergency

Powers

• Rule 307. Surveillance

• Rule 406. System 

Security

• Rule 517. Real-Time 

Market Monitoring

• Rule 1302. Position 

Limits or Position 

Accountability

• Rule 1303. Risk Controls 

for Trading

Compliance Manual (Exhibit 

O)
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(ii) the fulfillment of the

responsibilities and obligations of 

the swap execution facility; and

(C) periodically conduct tests to verify 

that the backup resources of the 

swap execution facility are sufficient 

to ensure continued-

(i) order processing and trade 

matching; 

(ii) price reporting;

(iii) market surveillance and 

(iv) maintenance of a comprehensive 

and accurate audit trail.

necessary or appropriate to respond to the Emergency.

As stated in Rule 307 (“Surveillance”), RTX SEF has contracted with 

Eventus for the performance of market surveillance, trade practice, and 

audit trail surveillance, although RTX SEF retains ultimate responsibility 

for the oversight of each Participant. Under Rule 307, anyone who is 

subject to RTX SEF’s rules must provide Eventus with any information it 

requests (provided that the request falls within the scope of Evenus’s 

duties).

Rule 406 makes Participants responsible for controlling and monitoring 

the use of all User IDs that RTX SEF issues to them or their Authorized 

Traders. Rule 406 obliges each Participant (1) to ensure that each 

Person accessing the Trading System using such User IDs is assigned a 

unique password that is only used by the Person to whom it is assigned 

and (2) to promptly notify RTX SEF upon becoming aware of any 

unauthorized disclosure or use of such User IDs or passwords or access 

to RTX SEF or of any other reason for deactivating User IDs or 

passwords. Under Rule 406, each Participant is also bound by any 

actions taken through the use of such User IDs or passwords (other than 

any such actions resulting from the fault or negligence of RTX SEF), 

including the execution of transactions, whether or not such actions 

were authorized by such Participant or any of its Supervised Persons or 

executed by anyone other than an Authorized Trader of such 

Participant.

Under Rule 517, RTX SEF is required to monitor and evaluate trading, as 

well as general market data, in real time. This rule also permits RTX SEF 

to protect the integrity of the market through several system safeguards 

that prevent the entry of orders under enumerated circumstances.

To reduce the potential threat of market manipulation or congestion, 

RTX SEF is required under Rule 1302, as it deems necessary and 

appropriate, to adopt for each of the contracts of the RTX SEF position 

limits or position accountability limits for speculators, which RTX SEF is 

then further required to monitor on an ongoing basis for unusual 

activity.

• Section X.C. Disaster 

Recovery/Business 

Continuity 

Plan/Safeguards/Tests

Technology Questionnaire

(Exhibit V)

• Generally
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Under Rule 1303, RTX SEF may, in its discretion, take any action to 

reduce the potential for market disruption and impose a similar riskcontrol action taken by another market trading a Swap that is fungible 

with, or a substitute for, a Swap traded on the RTX SEF.

Under Section X.C. of the Compliance Manual, RTX SEF is required to 

comply with the requirements of Core Principal 14 generally—and 

specifically by requiring RTX SEF to ensure that the staff is educated on 

all system safeguards and that various tests are conducted annually 

through a third-party, including vulnerability and penetration scans to 

ensure systems and information are adequately secured.

Core Principle 15:

Designation of Chief 

Compliance Officer

(A) In general 

Each swap execution facility shall 

designate an individual to serve as a 

chief compliance officer.

The Board will appoint a Chief Compliance Officer. This appointee will 

have the background and skills necessary to fulfill the responsibilities of 

the position and will not be disqualified from serving under CEA § 8a(2)–

(3). Once appointed, only a majority vote of the Board may remove the 

appointee.

Rulebook (Exhibit M)

• Rule 202. Officers

• Rule 203. Chief 

Compliance Officer

Compliance Manual (Exhibit 

O)

• Section VIII.F. The Chief 

Compliance Officer

Operating Agreement of RTX 

SEF (RTX Fintech & Research 

LLC) in Exhibit G

• Section 3.4. Chief 

Compliance Officer

(B) Duties 

The chief compliance officer shall-

(i) report directly to the board or to 

the senior officer of the facility;

(ii) review compliance with the core 

principles in this subsection;

(iii) in consultation with the board of 

the facility, a body performing a 

function similar to that of a 

board, or the senior officer of the 

The Chief Compliance Officer shall:

(1) Report directly to the Board; 

(2) Oversee and review RTX SEF’s compliance with Section 5h of the 

CEA and any related rules adopted by the Commission; 

(3) Consult with the Board or the Chief Executive Officer, resolving 

any conflicts of interest that may arise, including:

o conflicts between business considerations and compliance 

requirements; and

o conflicts between business considerations and the 

requirement that RTX SEF provide fair, open, and impartial 

Rulebook (Exhibit M)

• Rule 203. Chief 

Compliance Officer

Compliance Manual (Exhibit

O)

• Section VIII.F. The Chief 

Compliance Officer

Operating Agreement of RTX 
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facility, resolve any conflicts of 

interest that may arise; 

(iv) be responsible for establishing 

and administering the policies 

and procedures required to be 

established pursuant to this 

section;

(v) ensure compliance with this 

chapter and the rules and 

regulations issued under this 

chapter, including rules 

prescribed by the Commission 

pursuant to this section; and 

(vi) establish procedures for the 

remediation of noncompliance 

issues found during compliance 

office reviews, look backs, 

internal or external audit 

findings, self-reported errors, or 

through validated complaints.

access as provided in Commission Rule 37.202.

(4) Establish and administer written policies and procedures 

reasonably designed to prevent violation of the CEA and any 

rules adopted by the Commission; 

(5) Take reasonable steps to ensure compliance with the Act and 

Commission Rules, including but not limited to the establishing 

and administering a compliance manual and provide employees 

a written code of ethics designed to prevent ethical violations 

and to promote honesty and ethical conduct; and

(6) Establish procedures for the remediation of noncompliance 

issues identified by the Chief Compliance Officer through a 

compliance office review, look- back, internal or external audit 

finding, self-reported error, or validated complaint.

SEF (RTX Fintech & Research 

LLC) in Exhibit G

• Section 3.4. Chief 

Compliance Officer

(C) Requirements for procedures 

In establishing procedures under 

subparagraph (B)(vi), the chief 

compliance officer shall design the 

procedures to establish the handling, 

management response, remediation, 

retesting, and closing of

noncompliance issues.

The Chief Compliance Officer shall establish and follow appropriate 

procedures for the handling, management response, remediation, 

retesting, and closing of noncompliance issues.

Rulebook (Exhibit M)

• Rule 203. Chief 

Compliance Officer

• Rule 204. Compliance 

Department

Compliance Manual (Exhibit 

O)

• Section VIII.F. The Chief 

Compliance Officer

(D) Annual reports

(i) In general

In accordance with rules 

prescribed by the Commission, 

the chief compliance officer shall

annually prepare and sign a 

report that contains a 

The Chief Compliance Officer shall prepare and sign an annual 

compliance report. Such annual compliance report for the year since the 

end of the previous review period will contain the following 

information: 

(1) description of the swap execution facility’s written policies and 

procedures, including the code of ethics and conflict of interest 

policies; 

Rulebook (Exhibit M)

• Rule 203. Chief 

Compliance Officer

Compliance Manual (Exhibit 

O)

• Section VIII.F. The Chief 
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description of-

(I) the compliance of the 

swap execution facility 

with this chapter; and 

(II) the policies and 

procedures, including 

the code of ethics and 

conflict of interest 

policies, of the swap 

execution facility.

(ii) Requirements 

The chief compliance officer 

shall-

(I) submit each report 

described in clause (i) 

with the appropriate 

financial report of the 

swap execution facility 

that is required to be 

submitted to the 

Commission pursuant to 

this section; and 

(II) include in the report a 

certification that, under 

penalty of law, the 

report is accurate and 

complete.

(2) review of applicable Commission regulations and each 

subsection and core principle of section 5h of the Act, that, with

respect to each identifies the policies and procedures that are 

designed to ensure compliance, provides a self-assessment as to 

the effectiveness of these policies and procedures, and 

discusses areas for improvement and recommends potential or 

prospective changes or improvements to its compliance 

program and resources; 

(3) a list of any material changes to compliance policies and 

procedures since the last annual compliance report; 

(4) a description of the financial, managerial, and operational 

resources set aside for compliance including a description of the 

RTX SEF’s self-regulatory program’s staffing and structure, a 

catalogue of investigations and disciplinary actions taken since 

the last annual compliance report, and a review of the 

performance of disciplinary committees and panels; and 

(5) a description of any material compliance matters, including 

noncompliance issues identified through a compliance office 

review, look-back, internal or external audit finding, selfreported error, or validated complaint, and an explanation of 

how they were resolved. 

The Chief Compliance Officer shall sign a certification that, to the best of 

his or her knowledge and reasonable belief, and under penalty of law, 

the annual compliance report is accurate and complete. 

The Chief Compliance Officer shall submit the annual compliance report 

to the Board of Directors for its review and to the Commission within 

the time and manner specified by the Commission.

Compliance Officer

• Section VIII.G. Annual 

Compliance Review and 

Certification

Operating Agreement of RTX 

SEF (RTX Fintech & Research 

LLC) in Exhibit G

• Section 3.4. Chief 

Compliance Officer