September 3, 2019

Via CFTC Portal

Christopher J. Kirkpatrick

Secretary of the Commission

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: trueEX LLC Self-Certification of Rule Amendments – Physically Deliverable 

Bitcoin Swaps (trueEX LLC submission #2019-05S)

Dear Mr. Kirkpatrick: 

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (the “Act”), and 

Commission Regulation 40.6(a), trueEX LLC (“trueEX” or the “Exchange”) hereby 

submits to the U.S. Commodity Futures Trading Commission (the “Commission”) certain 

rulebook amendments related to the Bitcoin Physically Delivered Swap to be listed on the 

Tassat (formerly known as trueDigital) Division of trueEX. These rule amendments are 

listed in the table below. This contract will be listed on the trueEX SEF on the Tassat

Division. As such, only Eligible Contract Participants may trade this product. This contract 

is deemed to be a Permitted Transaction as it is not subject to the trade execution 

requirement in section 2(8)8 of the Act.

Summary of Amendments:

trueEX Rule Nature of Amendment

Rule 101. Amended the following definitions:

“Daily Settlement Price”, “Delivery Receiving 

Wallet”, “Final Notice”, “Initial Notice”, Maturity 

Date”, “Non-Primary Contract”, “Primary 

Contract”, “Settlement”, “Settlement Agent”, 

“Settlement Amount”, “Settlement Services 

Agreement”, “trueDigital Division”, “trueDigital 

Deliverable Swap Product”, “trueDigital Opening 

Price”, “trueDigital Products”, “trueDigital 

Reference Rate”, “trueDigital Spot Price Change”

Amended the definitions to reflect the 

name change from trueDigital to 

Tassat as clarifying amendments.
• Added the following definitions:

 “Force Majeure Event”

Definition added due to amendments 

to Rule 537 Limitation of Liability.

Amended the following Rules: 

Rules 513

Rules 1201 through 1208, 1210 through 1213, and 

1215

Amended to reflect the name change 

from trueDigital to Tassat as clarifying 

amendments.

Amended the following Rules:

Rule 514(b) Errors and Omissions in Handling 

Orders

Rule 522(c) Recordkeeping Requirements for 

Entering Orders into the Platform

Rule 537 Limitation of Liability

Rule 1207 Margins for Tassat Products and Early 

Termination Events

Clarifying amendments addressing 

CFTC Regulation 37.201(b)

Rule 1206 Price Limits and Trading Halts Clarifying amendments addressing 

CFTC Regulation 37.405

Rule 1215 XBT/USD Monthly Deliverable Swap Amendment to product terms and 

conditions addressing CFTC 

Regulation 37.201(b) (min trade/order 

size, min size precision, settlement 

Day Business Convention)

Each rule amendment summarized above is detailed in the redlined excerpts of the 

Exchange’s Rulebook attached as Exhibit A-1, with the final wording attached as Exhibit 

A-2 to this letter. 

trueEX certifies that these rules amendments comply with the Act and the Commission’s 

regulations thereunder, including the guidance issued by the Commission in CFTC Staff 

Advisory 18-14. trueEX’s analysis of the operation, purpose and effect of the proposed 

rule changes and their compliance with the Act, core principles and Commission’s 

regulations thereunder is included in the table above. There were no substantive opposing 
views expressed by the trueEX governing board or market participants to the rule 

amendments

trueEX certifies that this certification has been concurrently posted on the Exchange’s Web 

Site at http://www.trueex.com/rules-and-notices. These rules amendments will be 

effective no earlier than September 17, 2019.

If you have questions regarding this notice, please contact me at (312) 320-8934 or by 

email at fran@trueex.com.

Sincerely,

Fran Kenck

Chief Compliance Officer

Attachments:

Exhibit A-1 – Rule Amendments (marked)

Exhibit A-2 – Rule Amendments (clean)
1 

CHAPTER 1

DEFINITIONS

RULE 101. Definitions

When used in this Rulebook the following terms shall have the respective meanings as follows:

“Admin ID” means a unique identifier assigned by the Exchange to an Admin User, which enables the 

Exchange to identify the natural person accessing the administrative functionality of the Platform. 

“Administrative User” or “Admin User” means a natural person of the Participant, Sponsored Access 

Customer, Clearing Firm, or Settlement Agent, designated by the Participant, Sponsored Access Customer, 

Clearing Firm, or Settlement Agent, to access and use the Platform for administrative purposes only.

“Affiliate” means, with respect to any juridical entity, any Person that directly or indirectly through one or 

more intermediaries, controls such entity, is controlled by such entity, or is under common control with such 

entity.

“Amended Final Notice” shall have the meaning set forth in Rule 1210. 

“Appeal Panel” means a panel comprised of a chair and two individuals appointed by the Board to consider 

appeals under Chapter 6. 

“Applicable Law” means, with respect to any Person, any statute, law, regulation, rule or ordinance of any 

governmental or self-regulatory authority applicable to such Person, including the CEA and CFTC 

Regulations. 

“Authorized Contact” has the meaning set forth in Rule 538(a)(ii). 

“Authorized Representative” has the meaning set forth in Rule 310. 

“Authorized Trader” means (a) with respect to a Participant, a natural person who is either an employee of, 

or is an agent of, such Participant and who is duly authorized to exercise Trading Privileges of such 

Participant, and (b) with respect to a Sponsored Access Customer, a natural person who is either an employee 

of, or is an agent of, such Sponsored Access Customer and who is duly authorized to exercise Trading Access 

of such Sponsored Access Customer granted by the Sponsoring Participant. 

“Authorized User” means a natural person that is assigned a User ID or Admin ID. 

“Block Trade” means a “publicly reportable swap transaction”, as that term is defined in CFTC Regulation

§ 43.2, involving a Contract or Package Transaction that is a swap which:

(i) is not executed using the order book functionality of either the DCM or SEF

Trading System, but is executed pursuant to the rules and procedures of the Exchange, including 

on the SEF Trading System as provided for in CFTC No-Action Letter 17-60 expiring the earlier 

of 11:59 p.m. EST on November 15, 2020, or the effective date of any Commission action with 

respect to the issues discussed in No-Action Letter17-60; 

(ii) has a notional or principal amount at or above the minimum threshold applicable

to the Contract. For Package Transactions, each line item included in the Package Transaction 

must meet the appropriate minimum block size in order for the Package Transaction to be executed 

as a Block Trade as an RFQ to one; and 

(iii) is reported to the Exchange pursuant to Rule 542.

“Board” means the board of managers of the Exchange, which manages the Exchange and is constituted 

from time to time in accordance with the Operating Agreement.

“Bunched Order” is a single Order entered on the Platform on behalf of multiple Clients. 

“Business Day” means a day on which the Exchange is open for trading as shall be established, and may be 

revised from time to time, by the Exchange pursuant to Rule 503. 

Exhibit A
2

“CFTC” or “Commission” means the U.S. Commodity Futures Trading Commission.

“CFTC Regulations” means the rules and regulations promulgated by the CFTC, as amended.

“Chief Compliance Officer” or “CCO” means the individual appointed by the Board as the Exchange’s chief 

compliance officer for the SEF Trading System.

“Chief Executive Officer” means the individual appointed by the Board as the Exchange’s chief executive 

officer.

“Chief Regulatory Officer” or “CRO” means the individual appointed by the Board as the Exchange’s chief 

regulatory officer for the DCM Trading System.

“Cleared Transaction” means a Contract that is intended by a Participant to be submitted to a DCO for 

clearing and is eligible to be cleared by such DCO, including such Contracts that are subject to the Clearing 

Requirement or any Contract that is traded on the DCM Trading System.

“Clearing Firm” means a Person that is a member of a Clearing House that has been approved by such 

Clearing House to clear trades in any or all of the Contracts and has been admitted as a Clearing Firm by the 

Exchange.

“Clearing House” means a Derivatives Clearing Organization that has an agreement with the Exchange to 

provide clearing services with respect to any or all Contracts. 

“Clearing House Rules” means the certificate of incorporation or equivalent constitutive document, the bylaws and any rule, interpretation, stated policy, or instrument corresponding to any of the foregoing, in each 

case as adopted or amended from time to time by a Clearing House.

“Clearing Requirement” means the requirement to clear certain Contracts as the Commission has determined 

must be cleared pursuant to Section 2(h) of the CEA and the CFTC’s regulations promulgated thereunder.

“Client” means a person that has granted investment discretion to a Participant, Sponsored Access Customer 

or Direct Access Customer to enter Orders, execute Transactions and provide pre-execution and postexecution allocation services on, or through the Platform, in the name of and on behalf of such person.

“CME” means the Chicago Mercantile Exchange, Inc., or its successor.

“Commodity Exchange Act” or “CEA” means the Commodity Exchange Act, as amended from time to time.

“Confirmation” has the meaning set forth in Rule 546.

“Contract” means any contract, agreement, or transaction approved for trading on the Exchange and pursuant 

to the Rules. 

“Contract Market” has the meaning set forth in CFTC Regulation § 1.3(h).

“Contract Specifications” means, with respect to any Contract, the rules or other trading protocols containing 

specifications for such Contract, as adopted, amended, supplemented or otherwise modified from time to 

time by the Exchange.

“Control” means the possession, direct or indirect, of the power to direct or cause the direction of the 

management and policies of a Person, whether through the ownership of securities, by contract, or otherwise. 

The terms “controlling” or “controlled” shall have meanings correlative to the foregoing.

“Control” as used in the context of Rule 539 regarding RFQ for Required Transactions means an account 

for which a Client has granted trading discretion to another person via power of attorney or other written 

agreement to effect transactions without their consent. 

“Control Desk” has the meaning set forth in Rule 538.

“Continuing Session” has the meaning set forth in Rule 539.

“Core RFQ” is an application on the SEF Trading System that supports RFQ as a method of execution for 

certain Contracts and Package Transactions. 
3

“Cover” has the meaning set forth in Rule 539(b)(i)(D)

“Cross Trade” has the meaning set forth in Rule 520.

“CTI” means the customer type indicator set forth in Rule 522(d).

“Customer” means any person for whom a Participant transacts on behalf of, on or through the Platform, on 

a non-discretionary basis.

“Daily Settlement Price” shall mean the price determined pursuant to Rule 1208 and the Daily Settlement 

Price Methodology for Bitcoin Swap Contracts (available on the Exchange’s Web Site) each Trading Day 

by the Exchange for each Maturity Date of the trueDigitalTassat Products. The Daily Settlement Price may 

go out four decimal places and may be a price that is not a minimum increment for trueDigitalTassat

Products. 

“DCM Trading System” means the electronic trading system of the DCM established and operated by the 

Exchange for the purpose of executing Transactions in Contracts listed by the Exchange. The DCM Trading 

System consists of an anonymous central limit order book and a facility for the reporting of Block Trades 

that are executed pursuant to Rule 542.

“Definitive Final Notice” shall have the meaning set forth in Rule 1210.

“Delivery” shall mean the transfer of the Reference Asset by the seller to the Delivery Receiving Wallet, 

evidenced by ten confirmations of such transfer in the blockchain. 

“Delivery Commencement Notice” shall have the meaning set forth in Rule 1210.

“Delivery Dispute Notice” shall mean written notice sent by a counterparty to the Settlement Agent that 

describes, with sufficient detail, the nature of such counterparty’s good faith belief that Final Notice is 

incorrect. 

“Delivery Funding Confirmation” shall have the meaning set forth in Rule 1210.

“Delivery Readiness Notice” shall have the meaning set forth in Rule 1210.

“Delivery Receiving Wallet” shall mean the digital wallet identified by the buyer as the digital wallet into 

which the Reference Asset shall be transferred on the Settlement Date, by seller, in fulfillment of delivery 

obligations related to a Transaction in a trueDigitalTassat Deliverable Swap Product. 

“De-registration Basis” means, with respect to a Person, any basis upon which the CFTC could, subject to 

applicable procedural requirements, refuse to register, register conditionally, or suspend or place restrictions 

upon the registration of such Person under § 8a(2) of the CEA.

“Derivatives Clearing Organization” or “DCO” has the meaning set forth in § 1a(15) of the CEA.

“Designated Contract Market” or “DCM” has the meaning set forth in CFTC Regulation § 1.3(h).

“Designated Self-Regulatory Organization” or “DSRO” shall, unless otherwise provided, have the meaning 

attributed to such term in CFTC Regulation § 1.3(ff).

“Direct Access Customer” means a person for whom a Participant has agreed to provide Trading Access 

using the Firm ID of the Participant. A Direct Access Customer may trade for its own account or for Clients.

“Direct Access Trader” means a natural person who is either an employee of, or an agent of, a Direct Access 

Customer and who is duly authorized to exercise Trading Access granted to a Direct Access Customer. 

“Director” means any member of the Board.

“Disciplinary Action” has the meaning set forth in Rule 601(c).

“Disciplinary Offense” has the meaning set forth in CFTC Regulation § 1.63(a)(6).

“Disciplinary Panel” means a Review Panel or a Hearing Panel appointed by the Board at the 

recommendation of the Chief Compliance Officer or the Chief Regulatory Officer to act in an adjudicative 

role and fulfill various adjudicative responsibilities and duties described in Chapter 6.
4

“DOJ” means the United States Department of Justice.

“DTCC” means DTCC Data Repository (U.S.) LLC.

“Electronic Audit Trail” has the meaning set forth in Rule 522(b)(i).

“Eligible Contract Participant” or “ECP” has the meaning set forth in § 1a(18) of the CEA and CFTC 

Regulation § 1.3(m).

“Emergency” means any occurrence or circumstance that in the opinion of the Exchange’s governing board, 

or a person or persons duly authorized to issue such an opinion on behalf of the Exchange’s governing board 

under circumstances and pursuant to procedures that are specified by rule, requires immediate action, and 

threatens, or may threaten, such things as the fair and orderly trading in, or the liquidation of or delivery 

pursuant to, any agreements, contracts, swaps or transactions or the timely collection and payment of funds 

in connection with clearing and settlement by a Clearing House, including:

(i) any manipulative or attempted manipulative activity;

(ii) any actual, attempted or threatened corner, squeeze, congestion, or undue 

concentration of positions; 

(iii) any circumstance which may materially affect the performance of agreements, 

contracts, swaps, or transactions, including failure of the payment system or the bankruptcy or 

insolvency of any Participant, Clearing Firm, or Settlement Agent;

(iv) any action taken by any governmental body, or any other registered entity, board 

of trade, market or facility which may have a direct impact on trading or clearing and settlement;

(v) any other circumstance that may have a severe, adverse effect upon the functioning 

of the Exchange.

“Emergency Action” has the meaning set forth in Rule 214(a).

“Emergency Rules” has the meaning set forth in Rule 214(a).

“Emergency Disciplinary Action” has the meaning set forth in Rule 618(a).

“End-User Clearing Exception” means the exception from the clearing requirement set forth in § 2(h)(7) of 

the CEA and related CFTC regulations.

“End-User Transaction” shall mean a Transaction exempt from the clearing requirement of § 2(h)(l) of the 

CEA because one of the counterparties to the Transaction is entitled to and has elected to use the End-User 

Clearing Exception.

“Exchange” means trueEX LLC.

“Exchange Access Committee” means the committee of the Board constituted in accordance with Rule 207.

“Exchange Official” means any Director or Officer of, or individual employed directly by, the Exchange or 

any individual rendering similar services to the Exchange under an administrative or similar agreement.

“Exchange Panel” has the meaning set forth in Rule 212(b).

“Exchange Proceeding” has the meaning set forth in Rule 215(a).

“Exchange Regulation Department” means all Exchange Officials or agents of the Exchange that assist the 

Exchange in the implementation, surveillance and enforcement of the Rules and Applicable Law.

“Final Decision” has the meaning set forth in CFTC Regulation § 1.63(a)(5).

“Final Notice” shall mean the notice sent by the Settlement Agent to its customers, on the Last Trading Day, 

pursuant to Rule 1210, that provides the Settlement Agent’s customers with notice of their open 

trueDigitalTassat Deliverable Swap Product positions and their Settlement obligations. 

“Firm ID” means a unique ID assigned by the Exchange to a Participant or to a Sponsored Access Customer, 

which is used to identify such Participant or such Sponsored Access Customer accessing the Platform. 
5

“Force Majeure Event” means any occurrence beyond a Person’s reasonable control, including acts of 

God, fires, floods, wars, sabotage, accidents, strikes or labor disputes. 

“Futures Commission Merchant” or “FCM” has the meaning set forth in § 1a(28) of the CEA.

“Hearing Panel” means a panel selected in accordance with Rule 610 that is authorized to perform such roles 

and subject to such obligations as Chapter 6 contemplates.

“Government Agency” means any governmental entity, body or agency of any government (including the 

United States, a State, or a foreign government).

“Iceberg Order” means an Order that shall be divided into a displayed portion and a reserve portion in 

accordance with a fixed display size designated in such Order.

“Immediate Relation” means, with respect to a natural person, a spouse, parent, child, or sibling of such 

natural person, in each case, whether by blood, marriage, or adoption, or any person residing in the home of 

such natural person or an Immediate Relation of such natural person.

“Immediate or Cancel Order” means an Order that requires all or part of the order to be executed immediately

at the stated price or better, and any remaining balance of the order is cancelled.

“Initial Notice” shall mean the notice sent by the Settlement Agent to its customers, on the Initial Notice 

Day, pursuant to Rule 1210, that provides the Settlement Agent’s customers with notice of their open 

trueDigitalTassat Deliverable Swap Product positions and their expected Settlement obligations.

“Initial Notice Day” shall have the meaning as provided in the Contract specifications set forth in Rule 1215.

“Interested Person” has the meaning set forth in Rule 215(a).

“Introducing Broker” or “IB” has the meaning set forth in § 1a(31) of the CEA.

“Investigation” means an investigation conducted by the Exchange Regulation Department pursuant to 

Chapter 6.

“Investigative Report” has the meaning set forth in Rule 603(b).

“Independent Software Vendor” or “ISV” means a person that provides a Participants or Sponsored Access 

Customers technology other than that of the Exchange that provides order routing, front-end trading 

applications, aggregator functionality or a combination thereof. An ISV is not a Participant and does not 

execute or intermediate Transactions on the Exchange.

“ISDA” means International Swaps and Derivatives Association

“Last Trading Day” shall have the meaning as provided in the Contract specifications set forth in Rule 1215.

“Last Trading Time” shall have the meaning as provided in the Contract specifications set forth in Rule 

1215.

“LCH” means LCH.Clearnet Limited.

“Limit Order” means an Order to purchase or sell a Contract at a specified price or better.

“Liquidity Provider” means a Participant authorized by the Exchange to participate in a Liquidity Provider 

program under Rule 317.

“Major Swap Participant” has the meaning set forth in CFTC Regulation § 1.3(qqq).

“Market Data” has the meaning set forth in Rule 904. 

“Market Equilibrium Price” has the meaning set forth in Rule 539. 

“Market Notice” means a notice published by the Exchange on its Web Site.

“Matched Session” has the meaning set forth in Rule 539. 
6

“Maturity Date” In connection with trueDigitalTassat Products, Maturity Date shall have the meaning set 

forth in Chapter 12 of the Rules.

“Material Relationship”, with respect to a Director, has the meaning set forth in Appendix B to CFTC Part 

38, Core Principle 16(b)(2)(ii).

“NFA” means the National Futures Association.

“Nominating Committee” means the committee of the Board constituted in accordance with Rule 206.

“Non-Primary Contract” shall mean Contract(s), for each trueDigitalTassat Product listed by the Exchange, 

other than Primary Contracts. 

“Non-Public Information” means any information that the Exchange owns or otherwise deems confidential, 

including intellectual property belonging to: (i) the Exchange; or (ii) a third party, which property the 

Exchange receives on a confidential basis.

“Notice of Charges” shall have the meaning set forth in Rule 606(a).

“Officer” has the meaning attributed to such term in Rule 203.

“Order” means either a bid or an offer for a Contract, including the solicitation of a bid or offer though a 

Request for Quote.

“Package Transaction” means a transaction involving two or more Contracts or other instruments: 

(i) that is executed between two or more counterparties; 

(ii) that is priced or quoted as one economic transaction with simultaneous or near 

simultaneous execution of all Contracts and instruments; 

(iii) where at least one component is a Contract listed for trading on the Exchange; and

(iv) where the execution of each Contract or other instrument is contingent upon the 

execution of all other Contracts or instruments.

“Participant” means a person that is granted Trading Privileges by the Exchange to access or utilize the 

Platform.

“Participant Documentation” means the agreements (together with any applicable schedules, exhibits or 

appendices thereto required by the Exchange) in form and substance acceptable to the Exchange, which are 

required to be executed and delivered to the Exchange.

“Permitted Transaction” means any transaction involving a Contract that is not a Required Transaction. 

Each line item of a Package Transaction must not be subject to the trade execution requirement in § 2(h)(8) 

of the CEA.in order for the Package Transaction to be deemed a Permitted Transaction. 

“Person” or “person” has the meaning set forth in § 1a(38) of the CEA.

“Platform” means the Exchange electronic trade execution system that is used for trading Contracts on the 

DCM Trading System and/or the SEF Trading System, including any licensed software that is a part thereof 

from time to time, and any successor electronic trading system thereto. 

“Portfolio Terminations and Compactions” or “PTC” is an application on the SEF Trading System that 

supports RFQ as a method of execution for certain Contracts and Package Transactions. PTC offers 

flexibility to execute multiple line items in a single Package Transaction, quoting flexibility, multiple 

currencies and customization of swap terms. 

“Pre-Settlement Day” shall have the meaning as provided in the Contract specifications set forth in 

Rule1215.
7

“Primary Contract” shall mean the Contract(s), for each trueDigitalTassat Product listed by the Exchange, 

having a Maturity Date closest to the Settlement Date.

“Prime Broker” means a Person that agrees to permit a Participant to enter Orders on the Prime Broker’s 

behalf for the risk of the Prime Broker, and where the Participant (for itself or on behalf of its Customer or 

Client) intends to enter into a back-to-back transaction with the Prime Broker, as the case may be, pursuant 

to a Settlement Services Agreement between the parties providing for this limited agency relationship.

“Prime Broker Trade” means an Uncleared Transaction executed on the SEF Trading System between a 

Prime Broker and a counterparty with which the Prime Broker has a Settlement Services Agreement.

“Proprietary Account” has the meaning set forth in CFTC Regulation § 1.3(y).

“Public Director” means a Director who has been found by the Board, on the record, to have no Material 

Relationships with the Exchange in accordance with Rule 202(e).

“Public Participant” [means a person who would not be disqualified from serving as a Public Director by 

CFTC Regulation § 40.9(c)(2)][has the meaning set forth in CFTC Regulation § 40.9(c)(3)].1

“Real-Time Data” means swap transaction and pricing data described in Part 43 of CFTC Regulations, 

including all relevant appendices to Part 43 of the CFTC Regulations.

“Regulatory Oversight Committee” means the committee of the Board constituted in accordance with Rule 

208.

“Reporting Counterparty” has the meaning set forth in Rule 545.

“Request for Quote” or “RFQ” means an electronic message transmitted on the SEF Trading System by a 

Requestor soliciting bids or offers for a Contact or Package Transaction.

“Requester” means a Person that initiates a RFQ to transmit to other Persons on the SEF Trading System. 

“Required Swap Continuation Data” has the meaning given that term in CFTC Regulation 45.1

“Required Swap Creation Data” has the meaning given that term in CFTC Regulation 45.1.

“Required Transaction” means any Transaction involving a swap, either as a single Contract or a Package 

Transaction, that is subject to the trade execution requirement in § 2(h)(8) of the CEA and that is not a Block 

Trade or an End-User Transaction. A Package Transaction is a Required Transaction if one or more line 

items is subject to the trade execution requirement in § 2(h)(8) of the CEA.

“Respondent” has the meaning set forth in Rule 539(b)(i).

“Review Panel” means a panel selected in accordance with Rule 610 that is authorized to perform such roles 

and subject to such obligations as Chapter 6 contemplates.

“Rule” means any term or provision of the Participant Documentation, Rulebook, interpretations, orders, 

resolutions, advisories, notices, statements of policy, decisions, manuals and directives of the Exchange in 

part or in whole.

“Rulebook” means this trueEX LLC Rulebook.

“SEC” means the U.S. Securities and Exchange Commission.

“SEF Trading System” means the electronic trading system of the SEF established and operated by the 

Exchange for the purpose of executing Transactions in Contracts listed by the Exchange as identified in 

Chapter 12 of this Rulebook. The SEF Trading System consists of two different applications, Core RFQ 

and PTC for the purpose of executing Transactions using RFQ as a method of execution, a central limit order 

book for the execution of Transactions in contracts listed pursuant to Chapter 12 of this Rulebook, and a 

custom order book available for Required Transactions that are not listed on the DCM Trading System. The 

 1 [NTD: Pending final version of Conflicts of Interest Notice of Proposed Rulemaking.]
8

SEF Trading System shall also include a portal for reporting pre-negotiated Permitted Transactions in 

Contracts listed pursuant to Chapter 12 of the Rulebook.

“Self-Regulatory Action” has the meaning set forth in Rule 215(a).

“Self-Regulatory Organization” or “SRO” shall, unless otherwise provided, have the meaning set forth in 

CFTC Regulation § 1.3(ee) and, in addition, shall include a Derivatives Clearing Organization.

“Settlement” shall mean the Delivery of Reference Asset and the payment of the Settlement Amount with 

respect to a Transaction in a trueDigitalTassat Deliverable Swap Product.

“Settlement Agent” shall mean a Person acceptable to the Exchange that (a) provides cash settlement 

services for Participants and their Customers and/or Clients for final settlement of trueDigitalTassat

Products; (b) provides cash settlement services throughout the lifecycle of a Transaction, including 

margining, if Participants and their Customers and/or Clients are unable to do so, (c) set, monitor, and 

manage collateral limits for Participants and their Customers and/or Clients on the SEF Trading System, 

and/or (d) provide prime brokerage services to allow for Participants to enter into Prime Broker Trades on 

the SEF Trading System if the Settlement Agent is a Prime Broker. 

“Settlement Agreement” has the meaning set forth in CFTC Regulation § 1.63(a)(7).

“Settlement Amount” shall mean the amount of Settlement Currency the buyer of the Reference Asset is 

required to pay to settle a Transaction in a trueDigitalTassat Product.

“Settlement Currency” shall have the meaning as provided in the Contract specifications set forth in Rule 

1215. 

“Settlement Date” shall have the meaning as provided in the Contract specifications set forth in Rule1215.

“Settlement Price” means the official daily closing price for a Contract calculated each Business Day, as 

determined by the relevant Clearing Houses in accordance with Rule 804, and used for all open positions at 

the close of the daily settlement cycle.

“Settlement Services Agreement” shall mean a previously negotiated free-standing agreement between a 

Settlement Agent and a Participant, acceptable to the Exchange, governing, without limitation, the execution, 

margining, performance and settlement of trueDigitalTassat Deliverable Swap Products, including 

applicable collateral management, credit support and default provisions for such Participant and its 

Customers and/or Clients.

“Settlement Window” shall mean the trading activity from the period of time beginning at 4:15 pm and 

ending at 4:30 pm New York local time each Trading Day.

“Serious Disciplinary Offense” means, with respect to a natural person, that such person committed any 

serious disciplinary offense, such as: (1) was found within the prior three years by a Final Decision of a SelfRegulatory Organization, an administrative law judge, a court of competent jurisdiction, or the CFTC to 

have committed a Disciplinary Offense; (2) entered into a Settlement Agreement within the prior three years 

in which any of the findings, or in the absence of such findings, any of the acts charged, included a 

Disciplinary Offense; (3) currently is suspended from trading on any Designated Contract Market, is 

suspended or expelled from membership with any Self-Regulatory Organization, is serving any sentence or 

probation or owes any portion of a fine imposed pursuant to either: (a) a finding by a Final Decision of a 

Self-Regulatory Organization, an administrative law judge, a court of competent jurisdiction or the CFTC 

that such person committed a Disciplinary Offense, or (b) a Settlement Agreement in which any of the 

findings or, in the absence a Settlement Agreement in which any of the findings, or in the absence of such 

findings, any of the acts charged, included a Disciplinary Offense; (4) currently is subject to an agreement 

with the CFTC or any Self-Regulatory Organization not to apply for registration with the CFTC or 

membership in any Self-Regulatory Organization; (5) currently is subject to or has had imposed on him 
9

within the prior three years a CFTC registration revocation or suspension in any capacity for any reason, or 

has been convicted within the prior three years of any of the felonies listed in §§ 8a(2)(D)(ii) through (iv) of 

the CEA; or (6) currently is subject to a denial, suspension or disqualification from serving on the 

disciplinary committee, arbitration panel or governing board of any “self-regulatory organization” as that 

term is defined in § 3(a)(26) of the Securities Exchange Act of 1934.

“Sponsored Access Customer” means a Person (other than a natural person or an ISV) in respect of which 

Sponsored Designation has occurred and is continuing. 

“Sponsored Designation” has the meaning set forth in Rule 316.

“Sponsoring Participant” means a Participant that is an FCM and in respect of which Sponsored Designation 

has occurred and is continuing.

“Subject Person” means any Clearing Firm, Participant, Sponsored Access Customer or Direct Access 

Customer.

“Swap Data Repository” or “SDR” has the meaning set forth in § 1a(48) of the CEA.

“Swap Dealer” has the meaning set forth in CFTC Regulation § 1.3(ppp).

“Swap Execution Facility” or “SEF” has the meaning set forth in CFTC Regulation § 1.3(rrrr).

“trueDigitalTassat Division” shall mean a separate operating group within trueEX LLC offering digital asset

Contracts for trading.

“trueDigitalTassat Deliverable Swap Product” shall mean the deliverable Contract described in Rule 1215.

“trueDigitalTassat Opening Price” shall mean a price that is calculated by the Exchange each Trading Day 

by taking the sum of (a) Daily Settlement Price from the prior Trading Day and (b) the trueDigitalTassat

Spot Price Change. On the first Trading Day of a newly listed Maturity Date for a Contract, the Daily 

Settlement Price used in the determination of the Opening Price shall be calculated by the Exchange using 

market standard cost of carry methodology.

“trueDigitalTassat Products” shall mean the digital asset Contracts listed for trading on the trueDigitalTassat

Division of the Exchange. 

“trueDigitalTassat Reference Rate” shall mean the trueDigitalTassat OTC Reference Rate available at 

https://indices.truedgtl.com/indices. 

“trueDigitalTassat Spot Price Change” shall mean a number calculated by the Exchange each Trading Day 

by subtracting (a) the average of trueDigitalTassat Reference Rate 30 second interval prices during the five 

minute period beginning 4:25 pm and ending 4:30 pm (New York local time) on the Trading Day prior to 

the date on which such number is calculated, from (b) the average of the trueDigitalTassat Reference Rate 

30 second interval prices for the five minute time period before the start of Trading Hours. 

“Technology Services Agreement” means the agreement(s) between the Exchange and the Technology 

Services Provider whereby technology services are provided to the Exchange.

“Technology Services Provider” means the organization, if any, which provides technology services to the 

Exchange.

“TRADEON Session” has the meaning set forth in Rule 539.

“Trading Access” shall mean the ability of (a) a Direct Access Customer to transmit Orders, RFQs and 

respond to RFQs, and execute Transactions electronically on the Exchange via access to a system provided 

by a Participant and (b) a Sponsored Access Customer to access the Platform directly by means of the 
36

market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, 

no Person shall knowingly execute or accommodate the execution of such Orders by direct or indirect means.

RULE 507. Market Disruption Prohibited

No Person shall engage in any trading, practice, or conduct on the Platform or subject to the Rules that 

violates bids or offers, or demonstrates intentional or reckless disregard for the orderly execution of 

transactions within one half hour prior to the expiration of Trading Hours on any given Business Day, or is, 

is of the character of, or is commonly known to the trade as, “spoofing,” (bidding or offering with the intent 

to cancel the bid or offer before execution), as described in § 4c of the CEA. 

No Person shall engage in any Exchange Activity that (a) demonstrates intentional or reckless disregard for 

the orderly execution of transactions during the closing period, (b) consists of placing one or more Order 

with an intent to cancel such Order(s) prior to execution, (c) submitting or cancelling Orders with an intent 

to overload the Platform, (d) submitting or cancelling bids or offers with an intent to delay another person’s 

execution of trades, or (e) submitting or cancelling multiple bids or offers to create an appearance of false 

market depth; provided, however, that these clauses (a) through (e) shall not apply to Block Trades.

RULE 508. Market Manipulation Prohibited 

No Person shall directly or indirectly manipulate, or attempt to manipulate, the price of any Contract. 

Corners and attempted corners are prohibited.

RULE 509. Prohibition of Misstatements

No Person shall knowingly make any misstatement of a material fact to the Exchange, any Exchange 

Official, or any committee of the Board or Exchange Panel or knowingly omit a material fact necessary in 

order to make the statement made, in light of the circumstances under which they were made, not misleading.

RULE 510. [RESERVED]

RULE 511. [RESERVED]

RULE 512. Supervision

A Participant shall establish, maintain and administer reasonable supervisory procedures to monitor the 

compliance of its Authorized Traders with the Rules and any applicable provisions of the CEA or CFTC and 

such Participant may be held accountable for the actions of its Authorized Traders.

RULE 513. Misuse of the Platform

It shall be a violation of these Rules to willfully permit unauthorized use of the Platform, to assist any Person 

in obtaining unauthorized access to the Platform, to trade on the Platform without an agreement and an 

established account with a Clearing Firm (if engaging in Cleared Transactions), a Settlement Agent (if 

engaging in TassattrueDigital Products) to alter the equipment associated with the Platform (except with the 

Exchange’s consent), to interfere with the operation of the Platform, to intercept or interfere with information 

provided thereby, or in any way to use the Platform in a manner contrary to the Rules.

RULE 514. Errors and Omissions in Handling Orders

(a) A Participant that inadvertently, through error or omission, fails to execute a 

Customer Order at the time it should have been executed may, upon discovery of such error or omission, 

execute such Customer Order at the best obtainable price. Such Customer Order shall be competitively 

executed and should be executed in the next available trading session for the applicable listed Contract, but 

in any event must be executed no later than the close of the next trading day and shall be reported to the 

Customer at the price at which the Customer Order actually executed. Unless otherwise agreed between 
37

Participant and the relevant Customer, if such price is to the advantage of the Customer, the Customer shall 

receive the benefit thereof; if not, the Customer shall receive such monetary adjustment as will afford the 

Customer the equivalent of the price at which such Order should and could have been executed. Full details 

of all transactions consummated hereunder shall be promptly provided to the Exchange Regulation 

Department upon request.

(b) A Participant that makes an error in the execution of a Customer Order that is related 

to the terms of a Contract, including but not limited to, account number, quantitynotional amount, contract 

month, tenor, rate/price or other details of the Contract necessary to effect a Transaction on the Platform, 

shall resolve the error as agreed between the Participant and the relevant Customer or the Participant's error 

handling policies. If no such agreement or policy exists, Participant shall resolve such error in a manner that 

is fair and equitable to the Customer and shall include allowing the Customer to retain all or a portion of the 

executed Transaction, compensating the Customer for such error or some other agreed upon resolution 

provided it is within the scope of the Participant’s error handing policies, if any. If the Customer elects not 

to retain all or a portion of the executed Transaction, the Participant may transfer the position resulting from 

the Transaction to a firm error account pursuant to Rule 806. A Participant must document in writing the 

circumstances surrounding the nature of the error and promptly provide such documentation to the Exchange 

Regulation Department upon request.

(c) This Rule 514 shall not be construed to contravene any instructions received from a 

Customer regarding any Customer Order prior to its execution, but shall be construed to permit execution of 

Customer Orders under the conditions last prescribed without additional instructions from the Customer.

RULE 515. [RESERVED] 

RULE 516. Withholding Orders Prohibited

A Participant shall not withhold or withdraw from the Platform any Order, or any part of an Order, for the 

benefit or on the instruction of any Person other than for the Customer for whom the Participant is placing 

the Order.

RULE 517. Priority of Customers’ Orders

Except as otherwise permitted under the Rules or Applicable Law, no person shall enter an Order into the 

Platform for its own account, an account in which it has a direct or indirect financial interest or an account 

over which it has discretionary trading authority, including an Order allowing discretion as to time and price 

if such person is in possession of any unsubmitted Order from a Customer that the Platform is capable of 

executing, unless such Customer provides such person with written consent to delay such Order.

RULE 518. Handling of Customer Orders

(a) General Prohibition.

(i) DCM Trading System - Except as otherwise permitted under the Rules or 

Applicable Law, no person in possession of a Customer Order shall knowingly take, directly or 

indirectly, the opposite side of such Order on the order book of the DCM Trading System for its 

own account, an account in which it has a direct or indirect financial interest, or an account over 

which it has discretionary trading authority.

(ii) SEF Trading System - Except as otherwise permitted under the Rules or Applicable 

Law, no Participant who is an FCM or Introducing Broker, and in possession of a Customer Order, 

may knowingly take, directly or indirectly, the opposite side of such Customer Order on the order 

book of the SEF Trading System for its own account, an account in which it has a direct or indirect 
40

(iii) In the case where a Participant has a Direct Access Customer that is also a 

Participant, such Participant may notify such Direct Access Customer in writing that it is the Direct 

Access Customer’s obligation to maintain the Electronic Audit Trail with respect to such Direct 

Access Customer’s Orders. If such Direct Access Customer consents, the Participant’s obligations 

to maintain an Electronic Audit Trail with respect to such Direct Access Customer may be satisfied 

by such Direct Access Customer; provided, however, that such Participant will remain liable in case 

such Direct Access Customer fails to maintain the Electronic Audit Trail for Orders transmitted 

through the Participant’s system.

(iv) Each Participant providing access to Authorized Traders via a FIX API or to Direct 

Access Traders shall provide to the Exchange in a form and manner prescribed by the Exchange 

information requested by the Exchange regarding the natural persons entering Orders and execution 

Transactions using the Firm ID of the Participant. The information requested may include name, 

telephone number and email address. 

(c) [RESERVED] Notwithstanding the foregoing in paragraph (b) above, A Participant can 

rely on electronic order routing or order execution systems of the Exchange to record the audit trail 

information it enters into the system in accordance with Commission requirements. The Exchange 

shall maintain all information on behalf of Participants for any information entered into the Platform

and shall provide such information to the Participant upon request in a timeframe sufficient for the 

Participant to meet their regulatory requirements. Participants must maintain any aspect of the audit 

trail that occurs outside of the Platform. 

(d) Customer Type Indicator (CTI) Codes. Each Clearing Firm must identify each transaction 

executed on the Platform on the record of transactions submitted to the Exchange with the correct CTI code. 

The CTI codes are as follows:

(i) CTI 1: Transactions initiated and executed by an individual member for his own 

account, for an account he controls or for an account in which he has ownership or financial interest;

(ii) CTI 2: Transactions executed for the proprietary account of a clearing member or 

non-clearing member firm;

(iii) CTI 3: Transactions where an individual member or Authorized Trader executes for 

the personal account of another individual member, for an account the other individual member 

controls or for an account in which the other individual member has ownership or financial interest;

(iv) CTI 4: Any transaction not meeting the definition of CTI 1, 2 or 3. (These should 

be non-member customer transactions).

RULE 523 Modification and Cancellation of Orders

(a) Any Order that has been entered into the Platform may be modified or cancelled unless and 

until it has been executed or has otherwise expired. Any such modification or cancellation requires that a 

modification order or cancellation order, as the case may be, with respect to the original Order be entered 

into the Platform. Such modification or cancellation will become effective upon receipt by the Platform of 

the modification order or cancellation order, as the case may be. 

(b) Every Order automatically expires at the end of the Trading Hours on the calendar day such 

Order is placed, in the event of any suspension or curtailment of trading, including halts, or in the case of 

any failure of the Platform.
45

SERVICES TO THE EXCHANGE (EACH, A “TRUEEX PARTY”) SHALL BE LIABLE TO ANY 

PERSON FOR ANY LOSSES, DAMAGES, COSTS OR EXPENSES ARISING FROM OR IN 

CONNECTION WITH, IN EACH CASE:

(i) AS A RESULT OF THEIR USE OF SOME OR ALL OF THE PLATFORM AND 

BY MAKING USE OF THE PLATFORM;

(ii) ANY FAILURE, MALFUNCTION, FAULT IN DELIVERY, DELAY, 

OMISSION, SUSPENSION, INACCURACY, ERROR, TERMINATION, OR ANY OTHER 

CAUSE, IN CONNECTION WITH THE PROVISION, PERFORMANCE, MAINTENANCE, OR 

USE OF, THE PLATFORM, WEB SITE, ANY INFORMATION OR SERVICES PROVIDED BY 

THE EXCHANGE OR ANY TRUEEX PARTY OR ANY FACILITIES OR TECHNOLOGY 

USED TO SUPPORT THE PLATFORM, WEB SITE, EXCHANGE OR EXCHANGE SERVICES 

INCLUDING ANY FAILURE TO PROVIDE ALL OR ANY PART OF THE PLATFORM, OR 

ANY INABILITY OF ANY PERSON TO VIEW, ENTER, EXECUTE OR CANCEL ORDERS 

OR TRANSACTIONS IN WHOLE OR IN PART;

(iii) ANY ERRORS OR INACCURACIES IN INFORMATION PROVIDED BY THE 

EXCHANGE, A TRUEEX PARTY, THE PLATFORM OR ANY PLATFORM SYSTEMS, 

SERVICES OR FACILITIES, ANY ELECTRONIC COMMUNICATION OF MARKET DATA 

OR INFORMATION, PRICE REPORTING SYSTEMS AND ANY AND ALL TERMINALS, 

COMMUNICATIONS NETWORKS, SERVERS, SOFTWARE, HARDWARE, AND 

FIRMWARE, WHETHER SUCH ERRORS OR INACCURACIES ARE A RESULT OF ANY 

ACTION OR INACTION OF THE EXCHANGE, A TRUEEX PARTY OR AN INDEPENDENT 

THIRD PARTY; 

(iv) THE CREDITWORTHINESS OF ANY PARTICIPANT, DIRECT ACCESS

CUSTOMER, CUSTOMER OR CLIENT; 

(v) ACTS OR OMISSIONS OF ANY SUBJECT PERSON, AUTHORIZED 

TRADER, AUTHORIZED REPRESENTATIVE, DIRECT ACCESS TRADER, CUSTOMER OR 

CLIENT THEREOF; OR

(vi) ANY UNAUTHORIZED ACCESS TO OR UNAUTHORIZED USE OF ANY 

EXCHANGE SYSTEMS, SERVICES OR FACILITIES BY ANY PERSON.

(vii) ANY FORCE MAJEURE EVENT, INCLUDING, BUT NOT LIMITED TO, THE 

UNAVAILABILITY OF THE BLOCKCHAIN AS REASONABLY DETERMINED BY THE 

EXCHANGE, AFFECTING THE EXCHANGE OR A CONTRACT; OR 

(viii) A PARTICIPANT’S OWN SECURITY OR THE INTEGRITY OF A 

PARTICIPANT’S TECHNOLOGY OR TECHNOLOGY SYSTEMS.

THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY REGARDLESS OF 

WHETHER A CLAIM ARISES IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR 

OTHERWISE AND REGARDLESS OF WHETHER THE EXCHANGE HAS BEEN ADVISED OF, OR 

OTHERWISE MIGHT HAVE ANTICIPATED, THE POSSIBILITY OF SUCH LOSSES, DAMAGES, 

COSTS OR EXPENSES. 

(b) UNLESS THE EXCHANGE OR A TRUEEX PARTY HAS BEEN FINALLY 

ADJUDICATED BY A COURT OF COMPETENT JURISDICTION TO HAVE ENGAGED IN GROSS 

NEGLIGENCE OR WILLFUL MISCONDUCT, THE EXCHANGE’S AND ANY TRUEEX PARTY’S 

TOTAL COMBINED AGGREGATE LIABILITIES SHALL NOT EXCEED $10025,000 FOR ALL 

LOSSES FROM ALL CAUSES SUFFERED BY ALL PERSONS ON A SINGLE DAY; $20050,000 FOR 
46

ALL LOSSES SUFFERED BY ALL PERSONS FROM ALL CAUSES IN A SINGLE CALENDAR 

MONTH; AND $1,0100,000 FOR ALL LOSSES FROM ALL CAUSES SUFFERED BY ALL PERSONS 

IN A SINGLE CALENDAR YEAR. IF THE NUMBER OF ALLOWED CLAIMS ARISING OUT OF 

ANY FAILURES OR MALFUNCTIONS ON A SINGLE DAY OR SINGLE MONTH CANNOT BE 

FULLY SATISFIED BECAUSE OF THE ABOVE DOLLAR LIMITATIONS, ALL SUCH CLAIMS 

SHALL BE LIMITED TO A PRO RATA SHARE OF THE MAXIMUM AMOUNT FOR THE 

RESPECTIVE PERIOD. IN NO EVENT SHALL THE TOTAL COMBINED AGGREGATE LIABILITY 

OF THE EXCHANGE AND ANY TRUEEX PARTY, FOR ALL CLAIMS ARISING OUT OF ANY 

FAILURES, MALFUNCTIONS, FAULTS IN DELIVERY, DELAYS, OMISSIONS, SUSPENSIONS, 

INACCURACIES, INTERRUPTIONS, TERMINATIONS OR ANY OTHER CAUSES IN 

CONNECTION WITH THE FURNISHING, PERFORMANCE, OPERATION, MAINTENANCE, USE 

OF OR INABILITY TO USE ALL OR ANY PART OF ANY OF THE EXCHANGE’S SYSTEMS OR 

SERVICES, OR SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH SYSTEMS OR 

SERVICES, INCLUDING THE SEF TRADING SYSTEM AND THE DCM TRADING SYSTEM, OR 

THE NEGLIGENCE OF THE EXCHANGE OR ANY TRUEEX PARTY, EXCEED $1,0100,000 IN ANY 

GIVEN CALENDAR YEAR. 

(c) NEITHER THE EXCHANGE NOR ANY TRUEEX PARTY SHALL BE LIABLE TO 

ANY PERSON FOR ANY DAMAGES, COSTS, LOSSES OR EXPENSES AND THE SUBJECT 

PERSON, CUSTOMER, OR CLIENT (AS THE CASE MAY BE) SHALL INDEMNIFY, PROTECT AND 

HOLD THE EXCHANGE AND ANY TRUEEX PARTY HARMLESS FROM AND AGAINST ANY 

AND ALL LOSSES, DAMAGES, COSTS OR EXPENSES BASED UPON, OR IN CONNECTION WITH 

ANY CLAIM BY A THIRD PARTY BASED UPON THE DELAY, OMISSION, SUSPENSION, 

INACCURACY, ERRORS OR TIMELINESS OR OTHER ACTS OR OMISSIONS OF SUCH SUBJECT 

PERSON OR ANY OF ITS OR THEIR AUTHORIZED USERS, CUSTOMERS, OR CLIENTS (AS THE 

CASE MAY BE) IN RESPECT OF TRANSACTIONS OR ANY RELATED DATA, INCLUDING IN 

CONNECTION WITH QUOTES, BIDS, OFFERS OR OTHER PRICE INFORMATION PROVIDED IN 

CONNECTION WITH OR RELATING TO ANY TRANSACTION, ANY REQUEST FOR QUOTE OR 

INDICATION OF INTEREST.

(d) NEITHER THE EXCHANGE NOR ANY TRUEEX PARTY MAKES ANY EXPRESS 

OR IMPLIED WARRANTIES OR REPRESENTATIONS RELATING TO THE EXCHANGE, THE 

PLATFORM OR ANY EXCHANGE SERVICES OR FACILITIES USED TO SUPPORT THE 

PLATFORM, INCLUDING ANY WARRANTIES OF MERCHANTABILITY OR WARRANTIES OF 

FITNESS FOR A PARTICULAR PURPOSE OR USE. THE EXCHANGE WILL PROVIDE ALL 

SERVICES ON AN “AS IS” AND “AS AVAILABLE” BASIS AT THE SOLE RISK OF THE SUBJECT 

PERSON, CUSTOMER, OR CLIENT, AS THE CASE MAY BE. FURTHERMORE, NEITHER THE 

EXCHANGE NOR ANY TRUEEX PARTY GUARANTEES OR MAKES ANY REPRESENTATION OR 

WARRANTY, EITHER EXPRESS OR IMPLIED, (i) AS TO THE VALIDITY, SEQUENCE, 

TIMELINESS, COMPLETENESS, ACCURACY OR CONTINUED AVAILABILITY OF ANY 

INFORMATION OR DATA MADE AVAILABLE ON OR THROUGH THE EXCHANGE., (ii) THAT 

THE EXCHANGE OR THE PLATFORM WILL OPERATE IN AN ERROR-FREE, SECURE OR 

UNINTERUPTED MANNER, OR (iii) THAT THE EXCHANGE OR ANY ASPECTS OF THE 

PLATFORM WILL BE FREE FROM VIRUSES OR OTHER HARMFUL COMPONENTS. NEITHER 

THE EXCHANGE NOR ANY TRUEEX PARTY SHALL HAVE A DUTY OR OBLIGATION TO 

VERIFY ANY INFORMATION DISPLAYED ON THE PLATFORM SYSTEM OR OTHERWISE. 

EACH SUBJECT PERSON, CUSTOMER, OR CLIENT ACKNOWLEDGES AND AGREES THAT 

NEITHER THE EXCHANGE NOR ANY TRUEEX PARTY SERVES OR SHALL SERVE AS THE 

PRIMARY BASIS FOR ANY DECISIONS MADE BY SUCH SUBJECT PERSON, CUSTOMER, OR 

CLIENT, AS THE CASE MAY BE, NOR SHALL THE EXCHANGE OR ANY TRUEEX PARTY BE 

DEEMED TO ACT AS AN ADVISOR OR FIDUCIARY OF ANY SUBJECT PERSON, CUSTOMER, 

OR CLIENT, AS THE CASE MAY BE. A PERSON ACCESSING THE EXCHANGE IS SOLELY 

RESPONSIBLE FOR THE SECURITY AND INTEGRITY OF THE PERSON’S TECHNOLOGY. A 

PERSON’S ACCESS TO THE EXCHANGE MAY BE INTERNET-BASED AND THE EXCHANGE 
47

HAS NO CONTROL OVER THE INTERNET OR A PERSON’S CONNECTIONS THERETO. ANY 

PERSON ACCESSING THE EXCHANGE ACKNOWLEDGES THAT THE INTERNET, COMPUTER 

NETWORKS, AND COMMUNICATIONS LINKS AND DEVICES NECESSARY TO ENABLE A 

PERSON TO ACCESS AND USE THE PLATFORM ARE INHERENTLY INSECURE AND 

VULNERABLE TO ATTEMPTS AT UNAUTHORIZED ENTRY AND THAT NO FORM OF 

PROTECTION CAN ENSURE THAT A PARTICIPANT’S DATA, HARDWARE, OR SOFTWARE OR 

THE PLATFORM OR OTHER EXCHANGE PROPERTY WILL BE FULLY SECURE. 

FURTHERMORE, NEITHER THE EXCHANGE NOR ANY TRUEEX PARTY SHALL HAVE AN 

OBLIGATION TO MONITOR OR VERIFY ANY INFORMATION DISPLAYED THROUGH THE 

PLATFORM.

(e) ANY DISPUTE ARISING OUT OF THE USE OF THE PLATFORM OR EXCHANGE 

SERVICES OR FACILITIES USED TO SUPPORT THE PLATFORM TO WHICH THE EXCHANGE 

OR ANY TRUEEX PARTY IS A PARTY SHALL BE CONSTRUED AND ENFORCED IN 

ACCORDANCE WITH THE LAWS OF THE STATE OF NEW YORK, WITHOUT REGARD TO ITS 

CONFLICT OF LAW PRINCIPLES. ANY ACTIONS, ARBITRATIONS, SUITS OR PROCEEDINGS 

SHALL BE BROUGHT WITHIN TWO ONE YEARS FROM THE TIME THE PERSON FILING THE 

CLAIM KNEW, OR SHOULD HAVE KNOWN, OF THE ACT OR TRANSACTION THAT IS THE 

SUBJECT OF THE DISPUTE. ANY SUCH ACTION, SUIT OR PROCEEDING MUST BE BROUGHT 

IN ANY FEDERAL OR STATE COURTS LOCATED IN THE BOROUGH OF MANHATTAN, THE 

CITY OF NEW YORK. THIS PROVISION SHALL IN NO WAY CREATE A CAUSE OF ACTION AND 

SHALL NOT AUTHORIZE ANY ACTION THAT WOULD OTHERWISE BE PROHIBITED BY THE 

RULES OF THE EXCHANGE. THE ALLOCATIONS OF LIABILITY IN THIS RULE 537 REPRESENT 

THE AGREED AND BARGAINED FOR UNDERSTANDING OF THE PARTIES, AND EACH PARTY 

ACKNOWLEDGES THAT THE OTHER PARTY’S RIGHTS AND OBLIGATIONS HEREUNDER 

REFLECT SUCH ALLOCATIONS. THE PARTIES AGREE THAT THEY WILL NOT ALLEGE THAT 

THIS REMEDY FAILS ITS ESSENTIAL PURPOSE.

(f) UNDER NO CIRCUMSTANCES WILL THE EXCHANGE OR ANY TRUEEX PARTY 

BE LIABLE TO ANY PERSON FOR ANY INDIRECT, INCIDENTAL, PUNITIVE, SPECIAL OR 

CONSEQUENTIAL DAMAGES, INCLUDING LOSS OF PROFITS, LOSS OF USE, BUSINESS 

INTERRUPTION, THE COST OF PROCUREMENT OF SUBSTITUTE GOODS, SERVICES OR 

TECHNOLOGY, OR CORRUPTION OR LOSS OF DATA.

(g) NOTWITHSTANDING ANY OF THE FOREGOING PROVISIONS, THIS RULE 537 

SHALL IN NO WAY LIMIT THE LIABILITY OF ANY PERSON ARISING FROM ANY VIOLATION 

BY SUCH PERSON OF THE CEA OR CFTC REGULATIONS THEREUNDER.

RULE 538 Control Desk

(a) Support.

(i) The control center of the Exchange (the “Control Desk”) provides support and 

problem management only to Clearing Firms, Participants, and Settlement Agents, and their 

Authorized Users.

(ii) In order to be eligible for Control Desk support, a natural person must first be 

identified to the Exchange by the relevant Participant, Clearing Firm, or Settlement Agent, as the 

case may be, as an authorized contact (“Authorized Contact”) or must be an Authorized User. The 

Control Desk provides support via a specified telephone number and during specified hours.
86

CHAPTER 12

TRUEDIGITAL TASSAT DIVISION

Note: Settlement Agents may not be required to be registered with the CFTC. As such, the CFTC does not 

regulate or have any oversight responsibilities for the Settlement Agents or the Settlement Services 

Agreements between the Settlement Agents and trueEX Participants. However, a Settlement Agent 

whose services include acting as a Prime Broker intermediating trades for Participants and their 

Customers and/or Clients may require CFTC registration. trueEx Participants should undertake 

their own due diligence to assess both the Settlement Agents and the terms and conditions of the 

Settlement Services Agreements.

RULE 1201. Scope

This chapter applies to the trading of trueDigitalTassat Products on trueEX, which shall be subject to the 

trueEx’s Rules, including this Chapter 12. In the event of an inconsistency between Chapters 1 through 10 

and this Chapter 12, Chapter 12 shall govern. All trueDigitalTassat Products shall be Uncleared 

Transactions. 

RULE 1202. Trading trueDigitalTassat Products 

Prior to entering an Order for a trueDigitalTassat Product, each Participant shall have agreements in place, 

including a Settlement Services Agreement, that satisfy the requirements of these Rules, and comply with 

Order and RFQ entry requirements for Uncleared Transactions that the Exchange shall establish from time 

to time. 

RULE 1203. Settlement Agent 

(a) A Person is eligible to become, and continue to be, a Settlement Agent for trueDigitalTassat

Products executed on or through trueEX by entering into a legally binding agreement with trueEX. The 

responsibilities of the Settlement Agent are to:

(i) Provide cash settlement services for Participants and their Customers and/or Clients 

for final settlement;

(ii) Provide cash settlement services throughout the lifecycle of a Transaction, 

including margining, if Participants and their Customers and/or Clients are unable to do so;

(iii) Set, monitor, and manage collateral limits for Participants and their Customers 

and/or Clients on the SEF Trading System and must use automated means to screen Orders using 

such collateral limits. trueEX shall provide Settlement Agent with means to facilitate such 

screenings via its Collateral Monitoring Tools, as described in Rule 1214;

(iv) Provide prime brokerage services to allow for Participants to enter into Prime 

Broker Trades on the SEF Trading System if the Settlement Agent is a Prime Broker. 

(v) Assist the Exchange in any investigation into potential violations of the Rules or 

Applicable Law which occur through or with respect to any Transaction executed by its customers; 

provided that such assistance must be timely and may include the Settlement Agent being required 

to produce documents, to answer questions from the Exchange, or to appear in connection with an 

investigation;

(vi) Maintain all required and necessary regulatory approvals or licenses to operate as a 

Settlement Agent;

(vii) Notify the Exchange upon becoming aware of any material changes to the 

information or documentation provided to the Exchange; and 
87

(viii) For any Person organized or located outside of the United States, such Person shall 

enter into a written agreement acceptable to the Exchange appointing a third party as its U.S. agent 

for service of process for purposes of CFTC Regulation §15.05, and shall provide the Exchange with 

a copy of the agreement and any change to such appointment.

(b) Withdrawal. A Settlement Agent may cease to act in that capacity subject to the termination 

provisions of its contractual agreement with the Exchange. 

(c) A Settlement Agent shall be solely responsible for controlling and monitoring the use of all 

Admin IDs issued to its Authorized Users by the Exchange. Settlement Agent shall notify the Exchange 

promptly upon becoming aware of any unauthorized access to the Platform or any unauthorized disclosure 

or use of any Admin ID assigned to any of its Authorized Users and of any other reason for terminating an 

Authorized User’s access or deactivating an Admin ID. Settlement Agent shall be bound by any actions 

taken by its Authorized Users (other than any such actions resulting from the fault or negligence of the 

Exchange), whether or not such actions were taken or authorized by such Settlement Agent.

(d) A Settlement Agent that has agreed to provide cash settlement services, including margining 

and final settlement, for trueDigitalTassat Products executed on trueEX by a Participant for its own account, 

or on behalf of the Participant’s Customers or Clients, must establish collateral limits for the account(s) for 

which it settles Transactions, as applicable, and use automated means to screen Orders using such collateral 

limits. trueEX shall provide Settlement Agent with means to facilitate such screenings via its Collateral 

Monitoring Tools, as described in Rule 1214.

RULE 1204. Execution Methods 

(a) Anonymous Order Book 

(i) All Orders are matched with each other and executed electronically through the SEF 

Trading System in accordance with an algorithm that gives first priority to Orders at the best price 

and priority among Orders entered at the same price based on the length of time such Order has been 

resting. 

(ii) Orders to buy or sell any trueDigitalTassat Product are subject to subsection (d) of 

this Rule and the minimum trading requirements specified in the relevant Contract rules. 

(iii) SEF Trading System shall perform a pre-trade collateral check on all Orders 

entered. If the Order is within the collateral limits set by the Settlement Agent, the Order shall be 

accepted, and is firm and executable.

(iv) All activity that takes place on Order Book of the SEF Trading System is 

anonymous and the names of the parties are not disclosed to the counterparties or to the market as a 

whole. 

(v) Without limiting the generality of the foregoing, the algorithm to match Orders 

entered in the order book of the SEF Trading System is based upon the following principles:

(A) Limit Order. A Limit Order will be executed when entered to the extent that 

there are resting contra-Orders, with any balance of such Limit Order to remain as a resting 

Order until such Limit Order is executed or is cancelled. Limit Orders must be entered with 

a user-defined limit price. All Limit Orders shall be cancelled by the SEF Trading System 

when an Authorized Trader logs out, and no later than at the conclusion of Trading Hours 

on each Trading Day. 

(B) Spread Trade. A spread trade shall consist of a transaction which has two 

components that are executed simultaneously: first the purchase of one Maturity Date of a 

given trueDigitalTassat Product, and second the sale of a different Maturity Date of the same 

trueDigitalTassat Product.

(vi) Modification and Cancellation of Orders shall be as provided in Rule 523.
88

(b) Request for Quote (“RFQ”)

(i) The SEF Trading System provides RFQ functionality as a method of execution 

through Core RFQ. 

(ii) RFQ allows a Requester to send an RFQ to buy or sell a Contract or Spread Trade 

to Respondents. trueEX has no restrictions on who is eligible to be a Requester or 

Respondent and provides all Participants with equal priority in receiving RFQs and 

responding to such RFQs. The protocols for executing a Transaction using Core 

RFQ can be found in Table 1204 below.

(iii) RFQ is a fully disclosed method of execution.

Table 1204 – Core RFQ Protocols

General 

1. Transactions on Core RFQ can be 1 (outright), or 2 (Spread Trade) line items

2. Single Reference Asset per Transaction

3. Each Respondent knows how many other Respondents there are but their names and 

actions are not disclosed to each other, only to Requester.

a. There is no requirement for Requester to select best price or wait for all 

Respondents to provide a price.

4. If a Respondent changes or cancels a price, the original price is no longer actionable by 

the Requester.

5. Requester can send target level or request to refresh price to all active Respondents in 

RFQ session.

RFQ Workflow

1. Requester transmits an RFQ to desired number of Respondents. 

o The session will automatically be cancelled if execution has not occurred by the 

earlier of 30 minutes from the time RFQ is sent, or market close. 

2. Respondent(s) receive notification of RFQ and can take the following actions:

o Pass (Respondent is not interested and will not receive any further updates on 

that specific RFQ session).

o Submit a price to the Requester (and subsequently may update or cancel a price 

that has already been sent).

o All prices sent by the Respondent are subject to Requester’s acceptance and final 

affirmation by Respondent before execution occurs.

3. Requester can take the following actions:

o Cancel the RFQ session

o Ask for prices to be refreshed

o Accept one of the Respondent’s prices, which starts an Affirmation Session that 

lasts for 30 seconds.

4. When an Affirmation Session starts, the selected Respondent can take the following 

actions:

o Execute. The execution must take place no later than 30 minutes after the initial 

RFQ was sent by Requester.

o Update the price that was accepted. RFQ session returns to step 3 for action by 

Requester (including acceptance of price from other Respondent).

o Cancel the price that was accepted

o Do nothing. Session expires
89

(c) Pre-Negotiated Trade Portal. 

(i) A Person may arrange with another Person for the execution of a trueDigitalTassat

Product listed on the SEF Trading System and submit such Transaction details to the Pre-Negotiated 

Trade Portal provided that they comply with Rule 524(c)(ii).

(ii) Transactions booked through the Pre-Negotiated Trade Portal are fully disclosed.

(d) Prime Broker Trades. 

(i) Any Participant that elects to use the anonymous Order Book must have a relationship with 

a Prime Broker. In the event a trade is executed between two Participants using the same Prime Broker, 

upon execution, the buyer of the swap will be deemed to be acting on behalf of the Prime Broker and the 

seller of the swap will be deemed to be acting as principal.

(ii) A relationship with a Prime Broker is not required for any fully disclosed method of 

execution; provided however, that each party to the Transaction has previously-negotiated freestanding 

agreements with each other.

(i) A Participant is not precluded from executing a Transaction using a fully disclosed 

method of execution as a Prime Broker Trade. In the event that a trade is executed between two 

Participants using the same Prime Broker, upon execution, the buyer of the swap will be deemed to 

be acting on behalf of the Prime Broker and the seller of the swap will be deemed to be acting as 

principal.

(ii) Notification of Prime Broker Trade. trueEX will provide a Transaction 

Confirmation pursuant to Rule 546 to the Prime Broker as counterparty to a Prime Broker Trade. 

The Participant acting on behalf of the Prime Broker must also notify the Prime Broker of a Prime 

Broker Trade if required to do so pursuant to the Settlement Services Agreement.

(e) Notwithstanding the foregoing, all Transactions executed in trueDigitalTassat Products are 

Permitted Transactions and pursuant to CFTC Regulation 37.9(c)(2), trueEX may offer any method of 

execution. 

RULE 1205. Trade Cancellation and Price Adjustments 

(a) Trade Cancellation and Price Adjustments. 

(i) Subject to this Rule, the Board or a designee of the Board has authority to adjust 

trade prices or cancel (“bust”) trades on the trueDigitalTassat Division.

(ii) A Prime Broker shall have the right to cancel any Prime Broker Trade, subject to 

the terms of paragraph (c).

(b) Trade Cancellation by the Board.

(i) The Board or a designee of the Board has authority to adjust trade prices or cancel 

(“bust”) trades on the trueDigitalTassat Division when such action is necessary to mitigate market 

disrupting events caused by the improper or erroneous use of the Platform, system defects, or for 

any reason deemed necessary by the Exchange needed to comply with Applicable Law.

(ii) trueDigitalTassat No Bust Ranges. The Board or a designee of the Board may not 

adjust trade prices or cancel (“bust”) trades on the trueDigitalTassat Division that fall within the 

following “no bust” ranges as determined by the Board or its designee.

Contract No Bust Range

XBT/USD Deliverable Swap The price equivalent of 5% of the average of the best bid and 

offer at the time of execution. 

(c) Trade Cancellation by the Prime Broker. A Prime Broker shall have the right to cancel a 

Prime Broker Trade that: 
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(i) is executed in excess of a limit established by the Prime Broker with respect to the 

Prime Broker Trade, 

(ii) was executed by a Participant not authorized by the Prime Broker, and/or

(iii) was executed for a product not authorized by the Prime Broker. 

Provided that the Prime Broker shall communicate the cancellation directly to the Exchange no later than 6 

hours (as defined by each Prime Broker in its Settlement Services Agreement) after the time of execution of 

the Prime Broker Trade, and indicate the reason for such cancellation.

(d) Any Prime Broker Trade cancelled pursuant to section (c) above will be deemed to be void ab initio.

RULE 1206. Price Limits and Trading Halts 

(a) Price Limits. trueDigitalTassat Products are not subject to daily price limits. 

(b) Trading Halts. The following price movements in trueDigitalTassat Products shall be a 

triggering event that shall result in a trading halt. For the avoidance of doubt, in the event of a trading halt, 

the trading of all Maturity Dates of trueDigitalTassat Products with the same Trading symbol will cease and 

resting Orders in the affected trueDigitalTassat Product, existing at the time of the halt shall be automatically 

cancelled, as provided in Rule 523. For any given Trading Day, the first triggering event(s) for trading halts 

shall be calculated based upon the trueDigitalTassat Opening Price, but may be adjusted by the Exchange, 

in its sole discretion, to account for price movements on the (a) Exchange when the prior calendar day is not 

a Trading Day and/or (b) underlying reference price, when price movements occur on a day which is not a 

Trading Day 

(i) Trading in a trueDigitalTassat Product shall be halted for two minutes if :a

Transaction the best bid in a Maturity Date occurs at a price that is less than the lowest offer in the 

order book and is greater than or equal to 25% above or below or more above the trueDigitalTassat

Opening Price of that Contract provided that there is at least one existing offer by a Participant other 

than the Participant that entered such offer (the bidTransaction that triggers an initial trading halt 

and each related Transaction bid that triggers a subsequent trading halt, if any, a “Triggering Price

Bid”); or

(ii) After trading commences following a two-minute trading halt, trading in the 

trueDigitalTassat Product shall be subject to an additional trading halt of three minutes if: a 

Transaction 

the best bid in a Maturity Date occurs at a price that is greater than or equal tois less than 

the lowest offer in the order book and is 10% or more above or below the most recent Triggering

Price; Event provided that there is at least one existing offer by a Participant other than the 

Participant that entered such offer ; or

the best offer in a Maturity Date is greater than the highest bid in the order book and is 10% 

or more below the most recent Triggering Event provided that there is at least one existing bid by a 

Participant other than the Participant that entered such bid.
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(iii) After trading commences following an additional three-minute trading halt, trading 

in the trueDigitalTassat Product shall be subject to further trading halts, of a duration of five minutes

apiece each time: if a Transaction 

the best bid in a Maturity Date occurs at a price that is greater than or equal to is less than 

the lowest offer in the order book and is 10% or more above or below the most recent Triggering

Price Event provided that there is at least one existing offer by a Participant other than the 

Participant that entered such offer; or

the best offer in a Maturity Date is greater than the highest bid in the order book and is10% 

or more below the most recent Triggering Event provided that there is at least one existing bid by a 

Participant other than the Participant that entered such bid.

RULE 1207. Margin for trueDigitalTassat Products and Early Termination Events

In accordance with Applicable Law, Participants trading trueDigitalTassat Products must comply with the 

following margin and other requirements:

(a) Margin Requirements. The Exchange shall set minimum margin requirements for 

trueDigitalTassat Products in collaboration with each Settlement Agent, as appropriate,at least weekly and 

will notify Participants and Settlement Agent of such requirements and the method of calculation. The 

margin methodology used by the Exchange and the Settlement Agent (if applicable) will be made available 

to Participants upon request.

(b) Additional Margin. The Settlement Agent, in its discretion, may require additional margin 

in excess of the minimum set by the Exchange if so requested by the counterparties to a Transaction or as 

agreed in the Settlement Services Agreement or related documentation.

(c) Initial Margin. Each Trading Day the Exchange will promptly notify the Settlement Agent 

of the Daily Settlement Price. Upon receipt of the Daily Settlement Price, the Settlement Agent will calculate 

the value of new positions established that day and shall promptly notify each counterparty of the required 

amount of initial margin. Each counterparty shall promptly deliver collateral in an amount sufficient to cover 

the required amount of initial margin.

(d) Variation Margin. Each Trading Day, the Exchange will promptly notify the Settlement 

Agent of the Daily Settlement Price. Upon receipt of the Daily Settlement Price, the Settlement Agent will 

calculate the current valuation of all open positions and notify each counterparty of the required amount of 

variation margin. Each counterparty shall promptly deliver collateral in an amount sufficient to cover the 

required amount of variation margin.

(e) Forms of Margin. Collateral allowed to meet initial and variation margin Requirements 

must be in a form required pursuant to Applicable Law and subject to the Settlement Services Agreement 

and any related documentation. 

(f) Failure to Pay Margin. If a counterparty fails to promptly provide the required margin, the 

Settlement Agent and/or the opposite counterparty shall have the rights and remedies provided in the 

Settlement Services Agreement. The Settlement Agent may, in addition to actions set forth under paragraph 

(g) of this section, elect to reduce or eliminate credit limits for such counterparty. In addition, the Exchange, 

in its discretion, may take disciplinary action as set forth in Chapter 6 of the Rulebook. 

(g) Early Termination Events or Events of Default. In the event of a termination event or event 

of default with respect to one or more counterparties to a Prime Broker Trade, a Prime Broker may terminate, 

effect early close-out, or take any other action with respect to one or more Prime Broker Tradesin accordance 
92

with applicable law and as provided in the relevant agreements, including without limitation a Settlement 

Services Agreement.

RULE 1208. Daily Settlement Prices for trueDigitalTassat Products

(a) Daily Settlement Prices shall be calculated each Trading Day by the Exchange for each 

Maturity Date of the trueDigitalTassat Products. The Daily Settlement Price may go out four decimal places 

and may be a price that is not a minimum increment for trueDigitalTassat Products. 

(b) Daily Settlement Prices will be calculated in accordance with the Daily Settlement Price 

Methodology for Bitcoin Swap Contracts (available on the Exchange’s Web Site).

(c) The Exchange reserves the right to take into account other factors in determining Daily 

Settlement Prices.

RULE 1209. Reserved 

RULE 1210. Final Settlement Procedures for trueDigitalTassat Deliverable Swap Products 

(a) All counterparties taking part in the delivery process for trueDigitalTassat Deliverable Swap 

Products must have a relationship with a Settlement Agent for the purposes of holding fiat currency until 

delivery of the Reference Asset has been confirmed.

(b) Final Settlement Procedures for trueDigitalTassat Deliverable Swap Products shall be 

agreed between trueEXTassat and each Settlement Agent. Such procedures shall be made available on the 

Exchange’s website. 

(c) Settlement Failure. In the event that a counterparty fails to fulfill its settlement 

obligations(payment related to initial margin, variation margin, or Settlement Amount, or to deliver the 

Reference Asset), then the opposite counterparty and/or the Settlement Agent shall have the rights and 

remedies provided in the Settlement Services Agreement. If a counterparty fails to deliver the Reference 

Asset, the final value of the Reference Asset shall be as stated in the (a) Settlement Services Agreement, or 

(b) the Transaction Confirmation plus a premium or fee as agreed upon by the counterparties. In addition, 

the Exchange, in its discretion, may take disciplinary action for any such Settlement failure, as set forth in 

Chapter 6 of the Rulebook. 

RULE 1211. Division of Digital Assets 

If at any time there is an event or process that results in the division of a digital asset (i.e., a “hard fork”) that 

is a Reference Asset, then the Exchange shall have the right, in its sole discretion, to take action to align the 

trueDigitalTassat Product position holder’s exposures with cash market exposures, as appropriate. 

Appropriate action may include, without limitation, excluding the new digital asset from the Reference 

Asset, including new digital asset in the Reference Asset, providing cash adjustments, or assigning newly

listed contract position to trueDigitalTassat position holders. 

RULE 1212. Swap Data Reporting 

(a) Counterparties shall comply with the requirements of Rule 545 and CFTC Regulations 

regarding the reporting, and correction, of Required Swap Creation Data and Required Continuation Swap 

Data. 

(b) In the event that the counterparties novate or terminate a Transaction, the Reporting 

Counterparty shall promptly notify trueEXTassat of such novation or termination.
93

RULE 1213. Settlement Services Agreements 

(a) The settlement services provided by a Settlement Agent with respect to any Contract, and 

the rights and obligations of buyers and sellers of trueDigitalTassat Products (including rights and 

obligations in respect of collateral management, initial margining and settlement, variation payments and 

performance at maturity) shall be governed by the Settlement Services Agreement entered into between the 

Settlement Agent and Settlement Agent’s customers.

(b) In the event of a conflict or inconsistency between the Settlement Services Agreement and 

the Rules, the Rules shall prevail with respect to any responsibilities or obligations of a Settlement Agent 

under such Settlement Services Agreement. 

RULE 1214. Collateral Monitoring Tools 

The Exchange facilitates collateral monitoring by Settlement Agents by providing Collateral Monitoring 

Tools. The Exchange will allow the Settlement Agent to pre-establish or “push” a collateral limit to the 

Exchange, which is decremented throughout a Trading Day as applicable Transactions are executed. 

Settlement Agents may adjust their pre-set limits intra-day with immediate effect.
94

RULE 1215. XBT/USD Monthly Deliverable Swap 

Contract Description This contract is a swap in which the counterparties agree to buy or 

sell, at a set price, a specified quantity of the Reference Asset at a 

specified future date. 

Symbol SWP-XBT-USD-[MYY]

Trading Division trueDigitalTassat

Reference Asset XBT – Bitcoin

Settlement Currency USD - United States Dollar

Variation Margin Currency USD - United States Dollar

Minimum Price Increment 0.01 USD

Quoting Convention Quantity of Contracts, quoted in whole numbers. Fractional number 

of Contracts is not permitted. 

Contract Size 1 XBT

Minimum Order/Trade Size 510 Contracts

Minimum Size Precision 51 Contracts

Trading Convention Buy or sell in the amount of Contracts agreed upon by the 

counterparties

Trade Date The date on which the parties enter the Transaction 

Maturity Date The last Friday of each of the nearest two serial months, and the 

nearest two months in the quarterly cycle (Mar, Jun, Sep, Dec).

Margin Contracts are subject to mandatory margining pursuant to Rule 1207

Initial Notice Day One USNY business day before the Last Trading Day 

Initial Notice Day Business 

Day Convention

Preceding 

Last Trading Day One USNY business day before the Pre-Settlement Day

Last Trading Time 5:00 pm New York local time on the Last Trading Day 

Last Trading Day Business 

Day Convention

Preceding 
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Pre-Settlement Day One USNY business day before the Maturity Date 

Pre-Settlement Day Business 

Day Convention 

Preceding 

Settlement Date The Maturity Date agreed upon by the parties, as specified in the 

Confirmation for the Transaction. 

Settlement Date Business 

Day Convention

PreceedingFollowing 

Settlement Method Physical delivery, as provided in Rule 1210

Clearing House None - Uncleared 

Speculative Position Limits • Overall Limit: 

55,000 contracts in aggregate for all trueDigitalTassat Products for 

the same Reference Asset.

• Primary Contract Limit: 

15,000 contracts in aggregate for the Primary Contract of all 

trueDigitalTassat Products for the same Reference Asset.

Reportable Levels 5 Contracts in aggregate for all trueDigitalTassat Products for the 

same Reference Asset.

Trading Hours Trading Hours will commence each Trading Day at 9 am New York 

local time and end each Trading Day at 5 pm New York local time, 

with the exception of the Last Trading Day and Last Trading Time 

defined above.

Holidays US – New York (USNY)