17 State Street › New York, NY 10004 › cboe.com

August 4, 2020

Submitted via CFTC Portal

Office of the Secretariat 

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street

Washington, DC 20581

Re: Submission of Cboe SEF, LLC Fee-related Rule (Submission No. 20-06) 

Dear Sir, Madam:

Pursuant to Section 5c(c) of the Commodity Exchange Act (the “CEA”) and 40.6(a) of the 

regulations of the Commodity Futures Trading Commission (the “Commission”), Cboe SEF, LLC 

(“Cboe SEF”) hereby notifies the Commission that it is publishing a revised fee schedule (the 

“Fee Schedule”) as a Fee-related Rule, adding a session-based fee and clarifying how the Fee 

Schedule complies with the CEA and Commission regulation. 

A marked copy of the Fee Schedule is attached hereto as Exhibit A, and a clean copy, as 

amended, attached hereto as Exhibit B. This Fee-related Rule also replaced in its entirety the 

previous version of the Fee Schedule filed as Exhibit K to Cboe SEF’s Form SEF, and an 

amendment to Cboe SEF’s Form SEF is accordingly being filed concurrently through the CFTC 

Portal. The revised Fee Schedule will be effective on August 18, 2020. 

Cboe SEF certifies that the Fee Schedule complies with the CEA and the Commission’s 

regulations. Cboe SEF has reviewed the swap execution facility core principles (“Core 

Principles”) as set forth in the CEA and has determined that the Fee Schedule complies with the 

requirements of impartial access in Core Principle 2 and Commission Regulation 37.202 

because all fees and any discounts will be applied on an impartial, fair and non-discriminatory 

manner and the Fee Schedule will be made transparent to all Participants. 

Cboe SEF charges Transaction fees on the basis of each Transaction executed on the SEF 

Trading System and such fees may vary depending on the Tenor and currency pair of each 

Contract. Additionally, in connection with each Transaction, Cboe SEF systematically identifies 

each Participant counterparty as either passive or aggressive (removing) and charges fees in 

respect of each such category of Participant counterparty. Specifically, Cboe SEF identifies as 
U.S. Commodity Futures Trading Commission

August 4, 2020

Page 2

17 State Street › New York, NY 10004 › cboe.com

“passive” the Participant counterparty whose Order resided on the order book and subsequently 

matched against an inbound Order, while Cboe SEF identifies as “aggressive” or “removing” the 

Participant counterparty submitting such inbound Order. Cboe SEF has determined to set fees 

applicable in respect of “passive” Participant counterparties at a lower rate in order to 

encourage liquidity providers to distribute pricing to Cboe SEF, reflecting the value that liquidity 

providers contribute to Cboe SEF’s market. 

In addition, in compliance with Core Principle 2 and Commission Regulation 37.200, the Fee 

Schedule does not incentivize manipulative trading or market abuse or impact Cboe SEF’s 

ability to perform its trade practice and market surveillance obligations under the CEA, and

Cboe SEF’s Regulatory Division will continue to monitor trading to seek to prevent manipulative 

trading and market abuse. The Fee Schedule also complies with the requirements for 

monitoring and trade processing in Core Principle 4 and Commission Regulation 37.401, and 

the recordkeeping and reporting requirements in Core Principle 10 and Commission 

Regulations 37.1000 and 37.1001. 

Cboe SEF further certifies that this submission has been concurrently posted on its website at 

http://markets.cboe.com/global/fx/sef/resources/. No substantive opposing views were 

expressed with respect to this Fee-related Rule. 

If you have any questions regarding this submission, please contact me at (646) 856-8814 or 

lshemie@cboe.com. 

Sincerely, 

/s/ Lisa Shemie

Lisa A. Shemie 

Associate General Counsel

Chief Legal Officer - Cboe SEF, LLC

Attachments 

cc: Matthew Jones, Division of Market Oversight, Commodity Futures Trading Commission
Submission Date – April 12, 2019August 4July XX31, 2020

Page KA-1

EXHIBIT A

DUES, FEES, AND OTHER CHARGES

A. List of all dues, fees, or other charges 

The only services for which Cboe SEF, LLC (“Cboe SEF”) will charge its Participants are trade 

execution services and, for some Participants, connectivity fees to access the SEF Trading System, as 

follows:

1. Transaction Fees: Transaction Fees will be charged on the basis of each Transaction, and 

may vary depending on the tenor and currency pair of each Contract. Different pricing may 

be charged depending on whether the Participant has acted in a “passive” or “removing” 

capacity in connection with each such Transaction. Cboe SEF shall determine, in its sole 

discretion, whether a Participant is acting in a “passive” or “removing” capacity. In 

connection with each Transaction, Cboe SEF systematically identifies each Participant 

counterparty as either passive or aggressive (removing) and charges fees in respect of each 

such category of Participant counterparty. Specifically, Cboe SEF identifies as “passive” the 

Participant counterparty whose Order resided on the order book and subsequently matched 

against an inbound Order, while Cboe SEF identifies as “aggressive” or “removing” the 

Participant counterparty submitting such inbound Order. 

2. Connectivity Fees: Participants may be charged connectivity fees to access the SEF Trading 

System. Cboe SEF will charge Connectivity Fees for each physical connection a Participant 

establishes with the SEF Trading System. Cboe SEF will pass through all data center crossconnect charges, if applicable. Cboe SEF may also charge fees on a per-session basis. 

B. Description of the basis for all dues, fees, or other charges 

There are two categories of Participants that can execute Transactions on Cboe SEF: A Trading Firm 

may execute Transactions on behalf of and as agent of a Prime Broker; and a Principal Trading Firm 

may execute Transactions on its own behalf. Cboe SEF charges Participants that are Trading Firms or 

Principal Trading Firms a Fee for each Transaction executed on the SEF Trading System. The Fee is 

based on the Notional Amount in USD of each Transaction and is charged as a dollar amount per 

USD million of Notional Amount. A minimum Transaction Fee of USD 1.00 per Transaction is also 

charged in respect of any Order submitted to the SEF Trading System. 

Transaction Fees

Currency Pair Tenor Passive Fee 

(in USD, per USD 1mm of 

Notional Amount)

Removing (Aggressing) Fee

(in USD, per USD 1mm of 

Notional Amount)

All All 5.00 10.00
Submission Date – April 12, 2019August 4July XX31, 2020

Page KA-2

Connectivity Fees

Physical Connectivity 

Pricing:

Bandwidth Installation Monthly Fee

1G and Below no charge $500.00 / connection

10G no charge $1,000.00 / connection

Session Charges: Monthly Fee

FIX Order Entry Free

FIX BookFeed 

(Market Data)

Free

ITCH Free
Submission Date – August 4, 2020

Page B-1

EXHIBIT B

DUES, FEES, AND OTHER CHARGES

A. List of all dues, fees, or other charges 

The only services for which Cboe SEF, LLC (“Cboe SEF”) will charge its Participants are trade 

execution services and, for some Participants, connectivity fees to access the SEF Trading System, as 

follows:

1. Transaction Fees: Transaction Fees will be charged on the basis of each Transaction, and 

may vary depending on the tenor and currency pair of each Contract. Different pricing may 

be charged depending on whether the Participant has acted in a “passive” or “removing” 

capacity in connection with each such Transaction. In connection with each Transaction, 

Cboe SEF systematically identifies each Participant counterparty as either passive or 

aggressive (removing) and charges fees in respect of each such category of Participant 

counterparty. Specifically, Cboe SEF identifies as “passive” the Participant counterparty 

whose Order resided on the order book and subsequently matched against an inbound 

Order, while Cboe SEF identifies as “aggressive” or “removing” the Participant counterparty 

submitting such inbound Order. 

2. Connectivity Fees: Participants may be charged connectivity fees to access the SEF Trading 

System. Cboe SEF will charge Connectivity Fees for each physical connection a Participant 

establishes with the SEF Trading System. Cboe SEF will pass through all data center crossconnect charges, if applicable. Cboe SEF may also charge fees on a per-session basis. 

B. Description of the basis for all dues, fees, or other charges 

There are two categories of Participants that can execute Transactions on Cboe SEF: A Trading Firm 

may execute Transactions on behalf of and as agent of a Prime Broker; and a Principal Trading Firm 

may execute Transactions on its own behalf. Cboe SEF charges Participants that are Trading Firms or 

Principal Trading Firms a Fee for each Transaction executed on the SEF Trading System. The Fee is 

based on the Notional Amount in USD of each Transaction and is charged as a dollar amount per 

USD million of Notional Amount. A minimum Transaction Fee of USD 1.00 per Transaction is also 

charged in respect of any Order submitted to the SEF Trading System. 

Transaction Fees

Currency Pair Tenor Passive Fee 

(in USD, per USD 1mm of 

Notional Amount)

Removing (Aggressing) Fee

(in USD, per USD 1mm of 

Notional Amount)

All All 5.00 10.00
Submission Date – August 4, 2020

Page B-2

Connectivity Fees

Physical Connectivity 

Pricing:

Bandwidth Installation Monthly Fee

1G and Below no charge $500.00 / connection

10G no charge $1,000.00 / connection

Session Charges: Monthly Fee

FIX Order Entry Free

FIX BookFeed 

(Market Data)

Free

ITCH Free