SwapEx Advisory Notice 01-4519
December44,2045June 3, 2019

Page 4 of 9

USD/ARS 1M, 2M, 3M N/A
USD/BRL 1M, 2M, 3M N/A
USD/CLP. 1M, 2M, 3M N/A
USD/CNY 41M, 2M, 3M, 12M N/A
USD/COP 1M, 2M, 3M N/A
USD/IDR 1M, 2M, 3M N/A
USD/KRW 1M, 2M, 3M N/A
USD/MYR 1M, 2M, 3M N/A
USD/PEN 41M, 2M, 3M N/A
USD/PHP 41M, 2M, 3M N/A
USD/RUB 1M, 2M, 3M N/A
USD/THB 1M, 2M, 3M N/A
USD/TWD 41M, 2M, 3M N/A

Through the Reverse RFQ functionality, a market participant (the “Sender”) may stream quotes for certain
Permitted Transactions that are not Cleared Contracts to any or all Participants and/or Authorized
Traders (each a “Recipient’) provided that both the Sender and each such Participant or Authorized
Trader have indicated to the Company in writing they are willing to transact with each other via the
Reverse RFQ functionality and, if a credit relationship has been established as permitted under Rule
524(c) between the Sender and a Participant or Authorized Trader, there is available credit. To initiate a
Reverse RFQ, the Sender must identify those Recipients to whom it will send quotes. A Recipient may
accept a quote from the Sender by either accessing and responding to the outstanding quotes under the
“Markets” tab (if the Authorized User is accessing the Trading System through a GUI) or submitting an
“order” (if the Authorized User is accessing the Trading System through an API). Such acceptance will be
communicated to the Sender, who then will have the opportunity to confirm that it remains willing to
execute a transaction at that quoted rate. The Sender generally has no more than 500 milliseconds twe-
seconds-for Reverse RFQ (the “Reverse RFQ Review Period”) in which to confirm or reject the
acceptance of the transaction at the quoted rate. During the Reverse RFQ Review Period:; (1) the RFQ
status will be set to “pending” and the Recipient can no longer make any edits to it; and (2) the Sender is
not permitted to stream the same price quote to any other market participant on the Trading Platform. If
the quote provided is confirmed by the Sender prior to expiration of the applicable Reverse RFQ Review
Period, the status of the RFQ will be updated to reflect completion of the transaction at the quoted rate. If
the Sender rejects or otherwise does not confirm acceptance of the transaction within the applicable
Reverse RFQ Review Period noted above, the Trading System will not execute a transaction between the
Sender and the Recipient of the quote. RFQs submitted through the Reverse RFQ functionality may be
partially filled.


SwapEx Advisory Notice 01-19

June 3, 2019

Page 4 of 9

USD/ARS 1M, 2M, 3M N/A
USD/BRL 1M, 2M, 3M N/A
USD/CLP. 1M, 2M, 3M N/A
USD/CNY 4M, 2M, 3M, 12M N/A
USD/COP 1M, 2M, 3M N/A
USD/IDR 1M, 2M, 3M N/A
USD/KRW 1M, 2M, 3M N/A
USD/MYR 1M, 2M, 3M N/A
USD/PEN 1M, 2M, 3M N/A
USD/PHP 1M, 2M, 3M N/A
USD/RUB 1M, 2M, 3M N/A
USD/THB. 1M, 2M, 3M N/A
USD/TWD 1M, 2M, 3M N/A

Through the Reverse RFQ functionality, a market participant (the “Sender”) may stream quotes for certain
Permitted Transactions that are not Cleared Contracts to any or all Participants and/or Authorized
Traders (each a “Recipient’) provided that both the Sender and each such Participant or Authorized
Trader have indicated to the Company in writing they are willing to transact with each other via the
Reverse RFQ functionality and, if a credit relationship has been established as permitted under Rule
524(c) between the Sender and a Participant or Authorized Trader, there is available credit. To initiate a
Reverse RFQ, the Sender must identify those Recipients to whom it will send quotes. A Recipient may
accept a quote from the Sender by either accessing and responding to the outstanding quotes under the
“Markets” tab (if the Authorized User is accessing the Trading System through a GUI) or submitting an
“order” (if the Authorized User is accessing the Trading System through an API). Such acceptance will be
communicated to the Sender, who then will have the opportunity to confirm that it remains willing to
execute a transaction at that quoted rate. The Sender generally has no more than 500 milliseconds for
Reverse RFQ (the “Reverse RFQ Review Period”) in which to confirm or reject the acceptance of the
transaction at the quoted rate. During the Reverse RFQ Review Period: (1) the RFQ status will be set to
“pending” and the Recipient can no longer make any edits to it; and (2) the Sender is not permitted to
stream the same price quote to any other market participant on the Trading Platform. If the quote
provided is confirmed by the Sender prior to expiration of the applicable Reverse RFQ Review Period, the
status of the RFQ will be updated to reflect completion of the transaction at the quoted rate. If the Sender
rejects or otherwise does not confirm acceptance of the transaction within the applicable Reverse RFQ
Review Period noted above, the Trading System will not execute a transaction between the Sender and
the Recipient of the quote. RFQs submitted through the Reverse RFQ functionality may be partially filled.


SwapEx Advisory Notice 01-4519
Becemberd4,2045June 3, 2019

Page 8 of 9

Field Name

Information required to be provided for trading

Standard RFQ

Reverse RFQ

CLOB

Rate

N/A

The Authorized User
must input a price for
the order; except that,
for a market order, the
ability to input a price in
the Trading System is
suppressed as the
order will be
automatically matched
with the best available
price on the CLOB/
Reverse RFQ.

The Authorized User
must input a price for
the Order; except that,
for a market order, the
ability to input a price in
the Trading System is
suppressed as the
Order will be
automatically matched
with the best available
price on the CLOB/
Reverse RFQ.

Order type

N/A

Market: a Market Order is an order to buy or sell
an instrument at the market bid or offer rate.

Limit (default option): a Limit Order is an order to
buy or sell an instrument at a rate (the limit rate)
that you specify (or better).

Expiry type

N/A

Good until Cancel Order (default option): Once
the order is placed, it will remain in the market
until executed or cancelled.

IOC (Immediate or Cancelled): Once the order is
placed, if it is not immediately executed it will be
cancelled.

Timed: Once the order is placed, it expires in a
defined number of seconds.

Custom:

LDN-Once the order is placed, it will expire at
close of London market on a date that the
Authorized User selects;

NY-Once the order is placed, it will expire at close
of New York market on a date that the Authorized
User selects;

SGP-Once the order is placed, it will expire at
close of Singapore market on a date that the
Authorized User selects;

TOK-Once the order is placed, it will expire at
close of Tokyo market on a date that the
Authorized User selects;

CD (Custom Date)-to configure a custom date, the
Authorized User must determine the date and

time of the order's expiration.



SwapEx Advisory Notice 01-19

June 3, 2019
Page 9 of 9
Information required to be provided for trading
Field Name
Standard RFQ Reverse RFQ CLOB
; Partial fills allowed (default option) or not;
Fill type NIA i ;
Minimum Fill amount (blank by default)
When specified, the
Derivatives Clearing
Allocations’ Organization and NIA NIA
Clearing Firm
information is required
at the allocation level.
Legal Entity of Trade xX xX xX
Counterparty”
Derivatives Clearing x N/AT xX
Organization®
Clearing Firm’ x N/A® x

: Optional field whose purpose is solely for transactions intended to be cleared.

? If an Authorized User is permissioned to trade for multiple legal entities, such Authorized User must select the
legal entity for which it is trading at the time the Authorized User submits the RFQ or order. The Trading System
maintains, as static data, the list of legal entities for which a particular Authorized User is permissioned to trade.
3 Only required for transactions intended to be cleared. If an Authorized User is authorized to submit trades on
behalf of a Participant, Authorized Trader or Customer for clearing to multiple Derivatives Clearing Organizations
and / or Clearing Firms, the Authorized User must select the applicable Derivatives Clearing Organization and/or
Clearing Firm at the time the order is submitted. The Trading System maintains, as static data, the list of
Derivatives Clearing Organizations to which a particular Authorized User is authorized to submit trades for clearing.
Although the Company currently only offers instruments that are not intended to be cleared or are available for
clearing at LCH.Clearnet Limited, it intends to support the trading of instruments cleared at other Derivatives
Clearing Organizations in the future.

* Reverse RFQ functionality currently does not support instruments that are intended to be cleared.


SwapEx Advisory Notice 01-19

June 3, 2019
Page 6 of 9

Appendix 2 — Order Specific Information required to be entered into the system for trading on the Trading
System, by functionality type

Field Name

Information required to be provided for trading

Standard RFQ

Reverse RFQ

CLOB

Currency pair

Authorized User must select from the list o

f listed products

Tenor

An Authorized User can
submit a request with
either a standard value
date (1 month, etc.), or
a customized value
date

An Authorized User can
select an instrument
with a standard tenor
from a list of pre-
defined instruments
available in the Trading
System

An Authorized User
can:

(a) Select an
instrument with a
standard tenor from a
list of pre-defined
instruments available in
the Trading System or
an instrument with a
customized value date
created that day by
another Authorized
User;

(b) Create an
instrument with a
customized value date
(“Indication of Interest’)
which will be listed in
the CLOB from the time
entered until 5 pm ET
on the day entered,
allowing any Authorized
Users to submit an
Order for that particular

instrument.



SwapEx Advisory Notice 01-19
June 3, 2019
Page 5 of 9

Appendix 1 — Static Information for trading on the Trading System, by functionality type

Information required to be provided for trading
Field Name
Standard RFQ Reverse RFQ CLOB

Legal Entity x x x
Identifier of
Participant
CFTC Xx xX X
Registration
Status of
Participant
U.S. Person x Xx x
Status of
Participant
Financial X x x
Entity Status
of Participant
CTI Code x x x
Whether xX x x
Trades will be
allocated



SwapEx Advisory Notice 01-4519
Decembert4,2015June 3, 2019

Page 9 of 9
Information required to be provided for trading
Field Name
Standard RFQ Reverse RFQ CLOB
Partial fills allowed (default option) or not;
Fill type N/A
Minimum Fill amount (blank by default)
When specified, the
Derivatives Clearing
4 Organization and
Allocations Clearing Firm N/A N/A
information is required
at the allocation level.
Legal Entity of Trade x x x
Counterparty”
Derivatives Clearing x N/At x
Organization®
Clearing Firm® xX N/A® Xx

+ Optional field whose purpose is solely for transactions intended to be cleared.

? if an Authorized User is permissioned to trade for multiple legal entities, such Authorized User must select the
legal entity for which it is trading at the time the Authorized User submits the RFQ or order. The Trading System
maintains, as static data, the list of legal entities for which a particular Authorized User is permissioned to trade.

* Only required for transactions intended to be cleared. If an Authorized User is authorized to submit trades on
behalf of a Participant, Authorized Trader or Customer for clearing to multiple Derivatives Clearing Organizations
and / or Clearing Firms, the Authorized User must select the applicable Derivatives Clearing Organization and/or
Clearing Firm at the time the order is submitted. The Trading System maintains, as static data, the list of
Derivatives Clearing Organizations to which a particular Authorized User is authorized to submit trades for clearing.
Although the Company currently only offers instruments that are not intended to be cleared or are available for
clearing at LCH.Clearnet Limited, it intends to support the trading of instruments cleared at other Derivatives
Clearing Organizations in the future.
* Reverse RFQ functionality currently does not support instruments that are intended to be cleared.



SwapEx Advisory Notice 01-19
June 3, 2019
Page 8 of 9

Information required to be provided for trading

Field Name

Standard RFQ

Reverse RFQ

CLOB

Rate

N/A

The Authorized User
must input a price for
the order; except that,
for a market order, the
ability to input a price in
the Trading System is
suppressed as the
order will be

automatically matched
with the best available

The Authorized User
must input a price for
the Order; except that,
for a market order, the
ability to input a price in
the Trading System is
suppressed as the
Order will be
automatically matched
with the best available

price on the CLOB/

price on the CLOB/
Reverse RFQ.

Reverse RFQ.

Order type

N/A

Market: a Market Order is an order to buy or sell
an instrument at the market bid or offer rate.

Limit (default option): a Limit Order is an order to
buy or sell an instrument at a rate (the limit rate)
that you specify (or better).

Expiry type

N/A

Good until Cancel Order (default option): Once
the order is placed, it will remain in the market
until executed or cancelled.

IOC (Immediate or Cancelled): Once the order is
placed, if it is not immediately executed it will be
cancelled.

Timed: Once the order is placed, it expires in a
defined number of seconds.

Custom:

LDN-Once the order is placed, it will expire at
close of London market on a date that the
Authorized User selects;

NY-Once the order is placed, it will expire at close
of New York market on a date that the Authorized
User selects;

SGP-Once the order is placed, it will expire at
close of Singapore market on a date that the
Authorized User selects;

TOK-Once the order is placed, it will expire at
close of Tokyo market on a date that the
Authorized User selects;

CD (Custom Date)-to configure a custom date, the
Authorized User must determine the date and
time of the order's expiration.



SWAPEX:’

June 3, 2019

BY ELECTRONIC SUBMISSION

Melissa Jurgens

Office of the Secretariat

U.S. Commodity Futures Trading Commission
Three Lafayette Centre

1155 21s Street, N.W.

Washington, D.C. 20581

Re: SwapEx CFTC Submission 01-19: Certification Pursuant to Commission Rule 40.6 —
Advisory Notice 01-19: “SwapEx Trading Procedures and Protocols”

Dear Ms. Jurgens:

Pursuant to Section Sc(c) of the Commodity Exchange Act (the “Act”) and Section 40.6(a) of the
regulations of the Commodity Futures Trading Commission (the “CFTC” or “Commission”),
SwapEx, LLC (“SwapEx”, or the “Company”) hereby notifies the Commission that it is issuing a
new Advisory Notice 01-19-SwapEx Trading Procedures and Protocols (“Advisory Notice 01-
19”) which amends and replaces the existing Advisory Notice 01-15-SwapEx Trading
Procedures and Protocols (“Advisory Notice 01-15”) revisions to which were filed with the
Commission on December 14, 2015.

A clean copy of Advisory Notice 01-19 is attached hereto as Exhibit A and a copy of Advisory
Notice 01-19 marked to show changes against Advisory Notice 01-15 is attached hereto as
Exhibit B. For purposes of Part 40, this new Advisory Notice 01-19 should be deemed to be
effective on June 18, 2019. SwapEx hereby certifies that: (i) Advisory Notice 01-19 complies
with the Act and the Commission’s regulations thereunder; and (ii) a notice and copy of this
submission is posted, concurrently with this filing, on SwapEx’s website. There were no
substantive opposing views to this Advisory Notice 01-19 provided by the SwapEx Board of
Directors.

In the event that you have questions, please contact the undersigned at (212) 339-1583 or
sspaner@statestreet.com.

Sincerely,

Dili Dgewwr °

Shelley Spaner
Chief Compliance Officer

Encl. (Exhibits A and B, Advisory Notice clean and redline versions)


SwapEx Advisory Notice 01-4519
December44,2045June 3, 2019
Page 2 of 9

credit. The Trading System will only match an Order for a Cleared Contract, with quotes for such
instruments from other market participants who have clearing arrangements at the same Derivatives
Clearing Organization for such instrument and have available credit. For all transactions in Permitted
Transactions that are not Cleared Contracts that are executed on the CLOB, the Trading System will
disclose to each Participant and/or Authorized Trader that is counterparty to the trade, the name of the
other counterparty to the trade after execution. For Cleared Contracts that are executed on the CLOB,
the Trading System will not disclose the name of any party to its counterparty before or after execution.

For an Order to be successfully submitted to the CLOB, the Authorized User needs to be properly
authenticated and provide the information tagged as relevant for CLOB trading listed in Appendices 1 and
2. Certain of this information is stored as static data within the Trading System, while the remainder of
this information must be entered by the Authorized User on an order by order basis.

Standing CLOB

Market participants can access the Standing CLOB by using the front-end graphical user interface (GUI)
made available by the Company or by making use of an application programming interface (API) enabling
the Participant or Authorized Trader to customize its own interface for access to the Standing CLOB. All
Orders on the Standing CLOB are delivered (pushed) in near real-time to all Authorized Users who are
logged-in to the CLOB. Trades executed on the Standing CLOB are communicated via a ticker on the
CLOB (the “CLOB Ticker’), which publishes all transactions executed on the CLOB (without identifying
the parties thereto) in near real-time. Participants and Authorized traders can trade on the Standing
CLOB book by either taking liquidity (hitting/lifting bids and offers) or adding liquidity (placing orders into
the book).

Indication of Interest (“lol”)

Market participants can access the lol functionality on the CLOB by using the front-end graphical user
interface (GUI) made available by the Company. Market participants can raise an lol, which will be
communicated to all Authorized Users who are logged-in to the CLOB via the GUI and simultaneously will
establish a spontaneous CLOB instance accessible to Authorized Users who are logged-in to the CLOB
via the GUI that will continue in existence until the end of the trading day. When submitting an IOI, an
Authorized User can define the currency pair as well as the value date and fixing date. All Orders
submitted via the lol functionality are delivered (pushed) in near real-time to all Authorized Users who are
logged-in to the CLOB via the GUI. Executed trades resulting from an Order submitted via the lol
functionality are communicated to all Authorized Users logged-in to the CLOB via the GUI via the CLOB
Ticker. Once a spontaneous lol has been created, all Authorized Users who are logged-in to the CLOB
via the GUI may add liquidity in response to the lol or, conversely, take liquidity on the CLOB generated
by the lol.

Request for Quote (RFQ) Functionality
Overview

The Trading System also supports two Request for Quote (“RFQ”) execution styles for Permitted
Transactions: Standard RFQ and Reverse RFQ. All trading through the Standard RFQ functionality and
Reverse RFQ functionality is done on a fully-disclosed, attributed basis (i.e., a market participant that is
party to a trade will be identified to the other market participant who is counterparty to the trade prior to
execution).

For a request to be successfully submitted on the Trading System, the Authorized User needs to be
properly authenticated and provide the information tagged as relevant for Standard RFQ or Reverse RFQ
trading listed in Appendices 1 and 2. Certain of this information is stored as static data within the Trading
System, while the remainder of this information must be entered by the Authorized User on an order by
order basis.


[Exhibit B]

SWAPEX’

December +4,2046June 3, 2019
To: SwapEx Participants
From: SwapEx, LLC

Re: Advisory Notice 01-195 - SwapEx Trading Procedures and Protocols (SwapEx CFTC
Submission #019-195)

SwapEx Rule 524 (Operation of the Trading System) provides a summary of the execution methods
available on the Trading System, including the Order Book and Request for Quote ("RFQ") functionalities.
It also provides that “[a]dditional information with respect to the operation of the Trading System, the
execution methods and credit and risk functionality is provided in the applicable user guide and other
specific information that the Company may make available to Participants, Authorized Traders and
Authorized Users.” This Advisory Notice updates and amends prevides-additional information to
thecontained in the existing Advisory Notice 01-15 — “SwapEx Trading Procedures and Protocols’
(SwapEx CFTC Submission #04-45){as amended and restated by SwapEx CFTC Submission #097-15;
the-Existing Advisory Notice-04-15"), and supplements the information contained in SwapEx Rule 524.
New Advisory Notice 01-19, which-describesd trading procedures and protocols of the Trading System
and provides updated timing requirements related to Standard and Reverse RFQ Review Periods.
plemented the informati Atained in SwapEx Rule 524. This notice amends-and-restatesreplaces
the. previous £xisting-Advisory Notice 01-15, which will be considered no longer in force.-te-supplementHt

ith further_informati -ding-the-method-of ution tules- forthe Tradi tem-
g soy

Capitalized terms used without definition herein shall have the meanings assigned to them in the
SwapEx, LLC Rulebook (as amended from time to time, the “Rulebook’).

Central Limit Order Book (CLOB)

Overview

The Trading System offers central limit order book functionality (the “CLOB") that is anonymous at the
time of execution. The matching priority with respect to an acceptance of any price quote is based on
price and, if prices are identical, then firm orders will be given priority over indicative prices and then on a
“first in, first out” basis. All instruments listed in the product specifications set forth in Chapter 11 of the
Rulebook are available for trading on the CLOB. For the most popular instruments, the CLOB supports
continuous streaming liquidity (the “Standing CLOB”). For other instruments, the Trading System
supports CLOB trading through user-initiated Indications of Interest (“lol”), enabling CLOB functionality,
as further detailed below, for more customized swap instruments.

Cleared Contracts executed over the CLOB will be delivered to supported Derivatives Clearing
Organizations and names of the Participants, Authorized Traders and/or Customers) who are party to the
trade will not be revealed to the counterparty to the trade. In order for a Participant or Authorized Trader
to participate in trading of Cleared Contracts, the applicable Participant must either be able to self-clear or
the Participant or Authorized Trader must have authorization to submit swaps executed on the Trading
System for clearing to at least one Clearing Firm.

For a Permitted Transaction that is not a Cleared Contract, the Trading System will only match an Order
with quotes on the CLOB for such instrument from market participants if both market participants have
indicated to the Company in writing they are willing to transact with each other and, if a credit relationship
has been established as permitted under Rule 524(c) between market participants, they have available


SwapEx Advisory Notice 01-19

June 3, 2019

Page 7 of 9
Information required to be provided for trading
Field Name
Standard RFQ Reverse RFQ CLOB
An Authorized User
can:
(a) Select an
instrument with a
standard fixing date
from a list of pre-
defined instruments
available in the Trading
System or an
An Authorized User can anne ale
An Authorized User can select an instrument created that day by
submit a request with with a standard tenor another Authorized
Fixing Date either a standard fixing from a list of pre- User:
date, or a customized defined instruments ,
fixing date. available in the Trading (b) Create an
System instrument with a
customized fixing date
(‘Indication of Interest”)
which will be listed in
the CLOB from the time
entered until 5 pm ET
on the day entered,
allowing any Authorized
Users to submit an
Order for that particular
instrument.
Size An Authorized User must enter into the Trading System, for each RFQ or
Order, either the base or terms quantity.
An Authorized User can
enter a request asking
for a response from
RFQ Maker(s)
expressed as a bid, an
offer, or both a bid and
Bid or Offer offer. The Authorized User must select the side of the

Additionally, an
Authorized User can
ask RFQ Makers(s) for
both a bid and an offer,
but limit their own
actions to select one or
the other

order.



SwapEx Advisory Notice 01-19
June 3, 2019
Page 3 of 9

Standard RFQ

Market participants can access the Standard RFQ functionality by using the front-end graphical user
interface (GUI) made available by the Company or by making use of an application programming
interface (API) enabling the Participant or Authorized Trader to customize its own interface for access to
the Standard RFQ functionality. All instruments listed in the product specifications set forth in Chapter 11
of the Rulebook are available for trading via the Standard RFQ functionality. For Permitted Transactions
that are not Cleared Contracts, a Taker (as defined below) may submit an RFQ composed of two
Contracts for the same currency pair but with different fixing dates and maturity/valuation dates.

To initiate a Standard RFQ, an Authorized User must connect to the Trading System and select either the
“Requests” tab (if the Authorized User is accessing the Trading System through a GUI) or submit a
“Request’ (if the Authorized User is accessing the Trading System through an API).

Through the Standard RFQ functionality, a Person (the “Taker”) may submit an RFQ to certain other
Persons (each a “Maker”) to which all such Makers may respond. A Taker may submit an RFQ fora
Cleared Contract through the Standard RFQ functionality to any or all Participants and/or Authorized
Traders who have indicated to the Company in writing that they intend to act as “RFQ Makers” on the
Standard RFQ functionality for such Cleared Contract; provided that the Taker and each such Participant
or Authorized Trader have clearing arrangements at the same Derivatives Clearing Organization for such
Cleared Contract and have available credit. A Taker may submit an RFQ for a Permitted Transaction that
is not a Cleared Contract through the Standard RFQ functionality to any or all Participants and/or
Authorized Traders, provided that both the Taker and each such Participant or Authorized Trader have
indicated to the Company in writing they are willing to transact with each other via the Standard RFQ
functionality. If a credit relationship has been established as permitted under Rule 524(c) (Credit and
Risk Limits) between the Taker and a Participant or Authorized Trader, there must be available credit.
RFQs submitted through the Standard RFQ are filled on an all or none basis.

Makers may choose to submit firm or indicative quotes via the Standard RFQ functionality. A Maker who
provides an indicative quote in response to an RFQ in the Standard RFQ functionality is provided the
opportunity, after a Taker has accepted such indicative price quote, to confirm that it remains willing to
execute a transaction at that quoted rate. The Maker generally has no more than one second (the
“Standard RFQ Review Period’) in which to confirm or reject the acceptance of the transaction at the
quoted rate. During the Standard RFQ Review Period: (1) the RFQ status will be set to “pending” and the
Taker can no longer make any edits to it; and (2) the Maker is not permitted to send the same price quote
to any other market participant on the Trading System. If the quote provided is confirmed by the Maker
prior to expiration of the applicable Standard RFQ Review Period, the status of the RFQ will be updated
to reflect completion of the transaction at the quoted rate. If the Maker rejects or otherwise does not
confirm acceptance of the transaction within the applicable Standard RFQ Review Period noted above:
(1) the Trading System will not execute a transaction between the Maker and Taker; and (2) the RFQ will
resume and the Taker can select another quoted rate to accept.

Reverse RFQ

Market participants can access the Reverse RFQ functionality: (1) to stream quotes by making use of an
application programming interface (API) enabling the Participant or Authorized Trader to customize its
own interface for access to the Reverse RFQ functionality; or (2) to receive streamed quotes using the
front-end graphical user interface (GUI) made available by the Company or by making use of an API
enabling the Participant or Authorized Trader to customize its own interface for access to the Reverse
RFQ functionality. The following instruments are available for Reverse RFQ Trading’:

(Currency Pair [_Non-Cleared Tenors [ Cleared Tenors ]

* The Company may make changes to list of instruments for Reverse RFQ trading on an on-going basis.


SwapEx Advisory Notice 01-4519
December44,2045June 3, 2019
Page 5 of 9

Appendix 1 — Static Information for trading on the Trading System, by functionality type

Information required to be provided for trading
Field Name
Standard RFQ Reverse RFQ CLOB

Legal Entity x xX xX
Identifier of
Participant
CFTC x x x
Registration
Status of
Participant
U.S. Person Xx Xx Xx
Status of
Participant
Financial x x x
Entity Status
of Participant
CTI Code Xx x x
Whether x x Xx
Trades will be
allocated



SwapEx Advisory Notice 01-4519
Decembert4,2045June 3, 2019

Page 7 of 9
Information required to be provided for trading
Field Name
Standard RFQ Reverse RFQ CLOB
An Authorized User
can:
(a) Select an
instrument with a
standard fixing date
from a list of pre-
defined instruments
available in the Trading
System or an
An Authorized User can instrument with a
An Authorized User can select an instrument customized fixing date
a" b created that day by
submit a request with with a standard tenor another Authorized
Fixing Date either a standard fixing from a list of pre- User:
.. " + ser,
date, or a customized defined instruments ,
fixing date. available in the Trading (b) Create an
System instrument with a
customized fixing date
(‘Indication of Interest”)
which will be listed in
the CLOB from the time
entered until 5 pm ET
on the day entered,
allowing any Authorized
Users to submit an
Order for that particular
instrument.
Si An Authorized User must enter into the Trading System, for each RFQ or
IZE . "
Order, either the base or terms quantity.
An Authorized User can
enter a request asking
for a response from
RFQ Maker(s)
expressed as a bid, an
offer, or both a bid and
Bid or Offer offer. The Authorized User must select the side of the

Additionally, an
Authorized User can
ask RFQ Makers(s) for
both a bid and an offer,
but limit their own
actions to select one or
the other

order.



SwapEx Advisory Notice 01-19
June 3, 2019
Page 2 of 9

Transactions that are not Cleared Contracts that are executed on the CLOB, the Trading System will

disclose to each Participant and/or Authorized Trader that is counterparty to the trade, the name of the
other counterparty to the trade after execution. For Cleared Contracts that are executed on the CLOB,
the Trading System will not disclose the name of any party to its counterparty before or after execution.

For an Order to be successfully submitted to the CLOB, the Authorized User needs to be properly
authenticated and provide the information tagged as relevant for CLOB trading listed in Appendices 1 and
2. Certain of this information is stored as static data within the Trading System, while the remainder of
this information must be entered by the Authorized User on an order by order basis.

Standing CLOB

Market participants can access the Standing CLOB by using the front-end graphical user interface (GUI)
made available by the Company or by making use of an application programming interface (API) enabling
the Participant or Authorized Trader to customize its own interface for access to the Standing CLOB. All
Orders on the Standing CLOB are delivered (pushed) in near real-time to all Authorized Users who are
logged-in to the CLOB. Trades executed on the Standing CLOB are communicated via a ticker on the
CLOB (the “CLOB Ticker’), which publishes all transactions executed on the CLOB (without identifying
the parties thereto) in near real-time. Participants and Authorized traders can trade on the Standing
CLOB book by either taking liquidity (hitting/lifting bids and offers) or adding liquidity (placing orders into
the book).

Indication of Interest (“lol”)

Market participants can access the lol functionality on the CLOB by using the front-end graphical user
interface (GUI) made available by the Company. Market participants can raise an lol, which will be
communicated to all Authorized Users who are logged-in to the CLOB via the GUI and simultaneously will
establish a spontaneous CLOB instance accessible to Authorized Users who are logged-in to the CLOB
via the GUI that will continue in existence until the end of the trading day. When submitting an IOI, an
Authorized User can define the currency pair as well as the value date and fixing date. All Orders
submitted via the lol functionality are delivered (pushed) in near real-time to all Authorized Users who are
logged-in to the CLOB via the GUI. Executed trades resulting from an Order submitted via the lol
functionality are communicated to all Authorized Users logged-in to the CLOB via the GUI via the CLOB
Ticker. Once a spontaneous lol has been created, all Authorized Users who are logged-in to the CLOB
via the GUI may add liquidity in response to the lol or, conversely, take liquidity on the CLOB generated
by the lol.

Request for Quote (RFQ) Functionality

Overview

The Trading System also supports two Request for Quote (“RFQ”) execution styles for Permitted
Transactions: Standard RFQ and Reverse RFQ. All trading through the Standard RFQ functionality and
Reverse RFQ functionality is done on a fully-disclosed, attributed basis (i.e., a market participant that is
party to a trade will be identified to the other market participant who is counterparty to the trade prior to
execution).

For a request to be successfully submitted on the Trading System, the Authorized User needs to be
properly authenticated and provide the information tagged as relevant for Standard RFQ or Reverse RFQ
trading listed in Appendices 1 and 2. Certain of this information is stored as static data within the Trading
System, while the remainder of this information must be entered by the Authorized User on an order by
order basis.


Exhibit A

SwWAPEX’

June 3, 2019
To: SwapEx Participants
From: SwapEx, LLC

Re: Advisory Notice 01-19 - SwapEx Trading Procedures and Protocols (SwapEx CFTC
Submission #01-19)

SwapEx Rule 524 (Operation of the Trading System) provides a summary of the execution methods
available on the Trading System, including the Order Book and Request for Quote (“RFQ”) functionalities.
It also provides that “[a]dditional information with respect to the operation of the Trading System, the
execution methods and credit and risk functionality is provided in the applicable user guide and other
specific information that the Company may make available to Participants, Authorized Traders and
Authorized Users.” This Advisory Notice updates and amends information contained in the existing
Advisory Notice 01-15 — “SwapEx Trading Procedures and Protocols” (as amended and restated by
SwapEx CFTC Submission #09-15), and supplements the information contained in SwapEx Rule 524.
New Advisory Notice 01-19, describes trading procedures and protocols of the Trading System and
provides updated timing requirements related to Standard and Reverse RFQ Review Periods. . This
notice replaces the previous Advisory Notice 01-15, which will be considered no longer in force.

Capitalized terms used without definition herein shall have the meanings assigned to them in the
SwapEx, LLC Rulebook (as amended from time to time, the “Rulebook”).

Central Limit Order Book (CLOB)

Overview

The Trading System offers central limit order book functionality (the “CLOB”) that is anonymous at the
time of execution. The matching priority with respect to an acceptance of any price quote is based on
price and, if prices are identical, then firm orders will be given priority over indicative prices and then ona
“first in, first out” basis. All instruments listed in the product specifications set forth in Chapter 11 of the
Rulebook are available for trading on the CLOB. For the most popular instruments, the CLOB supports
continuous streaming liquidity (the “Standing CLOB”). For other instruments, the Trading System
supports CLOB trading through user-initiated Indications of Interest (“lol”), enabling CLOB functionality,
as further detailed below, for more customized swap instruments.

Cleared Contracts executed over the CLOB will be delivered to supported Derivatives Clearing
Organizations and names of the Participants, Authorized Traders and/or Customers who are party to the
trade will not be revealed to the counterparty to the trade. In order for a Participant or Authorized Trader
to participate in trading of Cleared Contracts, the applicable Participant must either be able to self-clear or
the Participant or Authorized Trader must have authorization to submit swaps executed on the Trading
System for clearing to at least one Clearing Firm.

For a Permitted Transaction that is not a Cleared Contract, the Trading System will only match an Order
with quotes on the CLOB for such instrument from market participants if both market participants have
indicated to the Company in writing they are willing to transact with each other and, if a credit relationship
has been established as permitted under Rule 524(c) between market participants, they have available
credit. The Trading System will only match an Order for a Cleared Contract, with quotes for such
instruments from other market participants who have clearing arrangements at the same Derivatives
Clearing Organization for such instrument and have available credit. For all transactions in Permitted


SwapEx Advisory Notice 01-4519
Becemberi14,2045June 3, 2019
Page 3 of 9

Standard RFQ

Market participants can access the Standard RFQ functionality by using the front-end graphical user
interface (GUI) made available by the Company or by making use of an application programming
interface (API) enabling the Participant or Authorized Trader to customize its own interface for access to
the Standard RFQ functionality. All instruments listed in the product specifications set forth in Chapter 11
of the Rulebook are available for trading via the Standard RFQ functionality. For Permitted Transactions
that are not Cleared Contracts, a Taker (as defined below) may submit an RFQ composed of two
Contracts for the same currency pair but with different fixing dates and maturity/valuation dates.

To initiate a Standard RFQ, an Authorized User must connect to the Trading System and select either the
“Requests” tab (if the Authorized User is accessing the Trading System through a GUI) or submit a
“Request” (if the Authorized User is accessing the Trading System through an API).

Through the Standard RFQ functionality, a Person (the “Taker”) may submit an RFQ to certain other
Persons (each a “Maker”) to which all such Makers may respond. A Taker may submit an RFQ for a
Cleared Contract through the Standard RFQ functionality to any or all Participants and/or Authorized
Traders who have indicated to the Company in writing that they intend to act as “RFQ Makers” on the
Standard RFQ functionality for such Cleared Contract; provided that the Taker and each such Participant
or Authorized Trader have clearing arrangements at the same Derivatives Clearing Organization for such
Cleared Contract and have available credit. A Taker may submit an RFQ for a Permitted Transaction that
is not a Cleared Contract through the Standard RFQ functionality to any or all Participants and/or
Authorized Traders, provided that both the Taker and each such Participant or Authorized Trader have
indicated to the Company in writing they are willing to transact with each other via the Standard RFQ
functionality. -and_lif a credit relationship has been established as permitted under Rule 524(c) (Credit
and Risk Limits) between the Taker and a Participant or Authorized Trader, there is-must be available
credit. RFQs submitted through the Standard RFQ are filled on an all or none basis.

Makers may choose to submit firm or indicative quotes via the Standard RFQ functionality. A Maker who
provides an indicative quote in response to an RFQ in the Standard RFQ functionality is provided the
opportunity, after a Taker has accepted such indicative price quote, to confirm that it remains willing to
execute a transaction at that quoted rate. The Maker generally has no more than eight secendsone
second (the “Standard RFQ Review Period”) in which to confirm or reject the acceptance of the
transaction at the quoted rate. During the Standard RFQ Review Period:; (1) the RFQ status will be set to
“pending” and the Taker can no longer make any edits to it; and (2) the Maker is not permitted to send the
same price quote to any other market participant on the Trading System. If the quote provided is
confirmed by the Maker prior to expiration of the applicable Standard RFQ Review Period, the status of
the RFQ will be updated to reflect completion of the transaction at the quoted rate. If the Maker rejects or
otherwise does not confirm acceptance of the transaction within the applicable Standard RFQ Review
Period noted above:; (1) the Trading System will not execute a transaction between the Maker and Taker,
and (2) the RFQ will resume and the Taker can select another quoted rate to accept.

Reverse RFQ

Market participants can access the Reverse RFQ functionality: (1) to stream quotes by making use of an
application programming interface (API) enabling the Participant or Authorized Trader to customize its
own interface for access to the Reverse RFQ functionality; or (2) to receive streamed quotes using the
front-end graphical user interface (GUI) made available by the Company or by making use of an API
enabling the Participant or Authorized Trader to customize its own interface for access to the Reverse
RFQ functionality. The following instruments are available for Reverse RFQ Trading":

[ Currency Pair [_Non-Cleared Tenors | Cleared Tenors ]

* The Company may make changes to list of instruments for Reverse RFQ trading on an on-going basis.


SwapEx Advisory Notice 01-4519
December44,2045June 3, 2019

Page 6 of 9

Appendix 2 — Order Specific Information required to be entered into the system for trading on the Trading
System, by functionality type

Field Name

Information required to be provided for trading

Standard RFQ

Reverse RFQ

CLOB

Currency pair

Authorized User must select from the list of listed products

Tenor

An Authorized User can
submit a request with
either a standard value
date (1 month, etc.), or
a customized value
date

An Authorized User can
select an instrument
with a standard tenor

from a list of pre-
defined instruments
available in the Trading
System

An Authorized User
can:

(a) Select an
instrument with a
standard tenor from a
list of pre-defined
instruments available in
the Trading System or
an instrument with a
customized value date
created that day by
another Authorized
User;

(b) Create an
instrument with a
customized value date
(“Indication of Interest’)
which will be listed in
the CLOB from the time
entered until 5 pm ET
on the day entered,
allowing any Authorized
Users to submit an
Order for that particular
instrument.