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L ice CLEAR EUROPE

April 30, 2018

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: ICE Clear Europe Self-Certification Pursuant to Commission Rule 40.6 —
Clearing Rule Amendments

Dear Mr. Kirkpatrick:

ICE Clear Europe Limited (“ICE Clear Europe” or the “Clearing House”), a registered
derivatives clearing organization under the Commodity Exchange Act, as amended
(the “Act”), hereby submits to the Commodity Futures Trading Commission (the
“Commission”), pursuant to Commission Rule 40.6 for self-certification, the
amendments to its Delivery Procedures (the “Delivery Procedures”)! discussed herein.
The amendments are to become effective on the first business day following the tenth
business day after submission, or such later date as ICE Clear Europe may determine.

Concise Explanation and Analysis

ICE Futures Europe is amending its Delivery Procedures to make certain
modifications and clarifications to the delivery terms relating to the ICE Futures
Europe (“IFEU”) Robusta Coffee Futures Contract. The amendments also remove
outdated references and typographical errors, insert references to current ICE systems
and align naming conventions used throughout the Delivery Procedures.

The changes are intended to be consistent with changes made to the IFEU contract
specifications for the Robusta Coffee Futures Contract. In particular, the amendments
to the Delivery Procedures will shorten the delivery period from the delivery notice to
the final settlement day from 14 calendar days to 4 calendar days to reflect

' Capitalized terms used but not defined herein have the meanings specified in the ICE Clear Europe
Delivery Procedures. :

ICE Clear Europe Limited
Registered in England No.06219884
Registered office: Milton Gate, 60 Chiswell Street, London EC1Y 4SA.


suggestions from market participants that the current period was unnecessarily long.
A shorter period also more closely aligns with other similar contracts, including the
ICE Futures US Coffee Futures Contract.

As a result of this change, the amendments also remove the existing “Early Take Up”
concept as no longer necessary given the shorter settlement period.

The changes also remove the Delivery Documentation Summary section as
unnecessary in light of amendments to the IFEU contract specifications.

Compliance with the Act and CFTC Regulations

The rule amendments are potentially relevant to the following core principles: (C)
Participant and Product Eligibility and (E) Settlement Procedures, and the applicable
regulations of the Commission thereunder.

Product Eligibility. The amendments are intended to amend the Delivery
Procedures to reflect certain changes to the Robusta Coffee Futures Contract
specifications, in order to improve the settlement process in light of market
participant feedback and to better align with delivery procedures of other
futures contracts. The terms and conditions of the Robusta Coffee Futures
Contracts are not changing in any other material respect, and such contracts
will continue to be cleared by ICE Clear Europe in substantially the same
manner as before the transition (other than with respect to the amendments to
the Delivery Procedures). As a result, ICE Clear Europe believes that the
amendments are consistent with the requirements of Core Principle C and
Commission Rule 39.12(b).

Settlement Procedures. As noted above, the settlement period for the Robusta
Coffee Futures Contracts is being shortened from fourteen to four days. The
shorter settlement period should provide greater settlement certainty for
clearing members and other market participants as it reduces the time period
during which a default could occur. The amendments also make other
clarifications to the operation of the Delivery Procedures. As a result, ICE
Clear Europe believes the amendments are consistent with the requirements of
Core Principle E and CFTC Rule 39.14.

As set forth herein, the amendments consist of changes to the Delivery Procedures, a
copy of which is attached hereto.

ICE Clear Europe hereby certifies that the amendments comply with the Act and the
Commission’s regulations thereunder.

ICE Clear Europe has received no substantive opposing views in relation to the
proposed rule amendments.

ICE Clear Europe has posted a notice of pending certification and a copy of this
submission on its website concurrent with the filing of this submission.

ICE Clear Europe Limited
Registered in England No.06219884
Registered office: Milton Gate, 60 Chiswell Street, London EC1Y 4SA


If you or your staff should have any questions or comments or require further
information regarding this submission, please do not hesitate to contact the

undersigned at patrick.davis@theice.com or +44 20 7065 7738.

Very truly yours,
[P, Sawes2k Iea.t——~

Patrick Davis
Head of Legal and Company Secretary

ICE Clear Europe Limited
Registered in England No.06219884
Registered office: Milton Gate, 60 Chiswell Street, London EC1Y 4SA