CERTIFICATIONS PURSUANT TO SECTION Sc OF THE COMMODITY EXCHANGE
ACT, 7 U.S.C. §7A-2 AND COMMODITY FUTURES TRADING COMMISSION RULE 40.6,
17 C.F.R. §40.6

Thereby certify that:

(1) the amended Rules above comply with the Commodity Exchange Act, and the
Commodity Futures Trading Commission’s regulations thereunder;and

(2) concurrent with this submission, GFI Swaps Exchange LLC. posted on its website:

(a) a notice of pending certification of the above Rules with the Commission; and (b)
a copy of this submission

Kunmeth Skkoven

By: Kenneth Sklover

Title: Chief Compliance Officer
Date: October 19, 2020




GFI Swaps Exchange LLC

541. Errors, Corrections or Cancellation of Transaction Data

(d)The Company will not submit or agree to submit a correction or cancellation for the purpose of re-
reporting Swap Transaction and Pricing Data in order to gain or extend a delay in public dissemination
of accurate Swap Transaction and Pricing Data or to otherwise evade the reporting obligations in Part 43
of CFTC Regulations.

(i) Alternatively, for cleared swaps, the Facility may use an ex post facto review process
in which the counterparties determine that an error has occurred and correct the error.
The offsetting trade and the correct transaction must be executed and submitted for
clearing as quickly as technologically practicable, but no later than 24 hours after the
erroneous cleared swap was executed.

The Facility shall conduct an ex post facto review of the error trade, offsetting trade.
and correct trade on a T+1 basis. Such review will consider whether a transaction
cancellation or price adjustment will adversely impact market integrity, facilitate
market manipulation or other illegitimate activity, or otherwise violate the CEA.
Commission regulations, or the SEF’s rules.

The SEF must make an affirmative finding that there was an error as part of its ex post

facto review.

543. Post Trade Anonymity

(a) Pursuant to the Commission issuing final rule § 37.9(d), it is prohibited to disclose, directly

or indirectly, including through a third-party service provider, the identity of a counterparty
for swaps executed, pre-arranged or pre-negotiated anonymously on or pursuant to the rules
of a SEF and intended to be cleared at the time of execution.

(b) Prohibition on post-trade name give-up shall not apply to components of a package
transaction that are uncleared swaps or non-swap instruments. Examples include, but are not
limited by, swaps executed with a US Treasury hedge cleared bilaterally between the
counterparties, swaps executed as part of a hedge to an Interest Rate Option or Credit Option
and swaps executed as part of a package with an uncleared swap.

() The compliance date for swaps subject to the trade execution requirement under section
2(h)(8) of the CEA is November 1, 2020. The compliance date for swaps not subject to the
trade execution requirement under section 2(h)(8) of the CEA is July, 5, 2021.

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601. Block Trades.

(h) As permitted by CFTC No-Action Letter No. 17-60.44-18 expiring December 15,2045, |
expiring November 15,2020, a Block Trade in a Cleared Swap may be effected on the Trading Platform
by any means of interstate commerce, including, but not limited to, (i) through a Request for Quote
pursuant to Rule 508 or (ii) as a voice-executed trade or a Brokered Trade pursuant to Rule 509. Such a
Block Trade shall not be deemed to be a required transaction for the purposes of Chapter 5 (other than
Rules 535 and 536). Notwithstanding the foregoing, such a Block Trade may not be executed in the
Order Book or during a JIT session.

1001. Cleared Swaps
(a) Cancellation and Resubmission.

(i) As permitted by CFTC No-Action Letter 20-01 15-24 expiring June5,
2016 and until the effective date of any changes provided in the regulations, if the
Company determines that a transaction (including a transaction that is a component leg of
a Package Transaction) is rejected from clearing by a Derivatives Clearing Organization
(A) because of a clerical or operation al error or omission by the Company or by one of
the counterparties to the transaction or its agent, or (B) in the case of a component leg of
a Package Transaction, due to the sequencing of the submission of the component legs of
the Package Transaction, a new transaction, with terms and conditions that match the
terms and conditions of the original transaction, other than any such error or omission
and time of execution, may be executed and submitted for clearing without having been
executed pursuant to the methods set forth in CFTC Regulation 37.9(a)(2). In the case of
transaction rejected from clearing because of a clerical or operational error or omission, if
the Company is able to identify and determine how to correct the error or omission, it
may execute the new transaction without obtaining the consent of the counterparties. If
the Company is unable to determine how to correct the error or omission, the
Company, at its election, may either (x) seek guidance from the counterparties with
respect to how to correct the error, after which the Company may then correct the
error with the consent of both counterparties, or (y) elect not to correct the error, in
which case the transaction will be treated as void ab initio and shall be cancelled by
the Company. In the case of a component leg of a Package Transaction rejected due
to sequencing, both Clearing Firms and each counterparty to the transaction must
consent to the submission of a new trade. Execution of a new trade and resubmission
of such trade to clearing pursuant to this subparagraph (i) must occur as quickly as
technologically practicable after the relevant Clearing Firm(s) receipt of notice of the
rejection by the Derivatives Clearing Organization, but, in any event, no later than 60
minutes from issuance of such notice. If the resubmitted transaction is rejected from
clearing, such transaction will be void ab initio and shall be cancelled by the Company.
The counterparties may not resubmit a new transaction a second time. The procedure
set forth in this subparagraph (i) is not available with respect to transactions that are
rejected from clearing for credit reasons.

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GFI Swaps Exchange LLC
Rule Implementation Submission 2020-01
October 19, 2020

1. The texts of the amended Rules are appended as Attachment A. Any additions are
underlined and any deletions are struck through.

2. The date of intended implementation for these rules is ten business days following the
filing of this submission.

3. Attached, please find a certification that: (1) these rules comply with the Commodity
Exchange Act (“Act”), and the Commission’s regulations thereunder; and (2) concurrent
with this submission, GFI Swaps Exchange LLC posted on its website: (i) a notice of
pending certification of the rule amendments with the Commission; and (ii) a copy of
this submission.

4. Acconcise explanation and analysis of the operation, purpose, and effect of each of the
amended rules appears below.

5. There were no opposing views expressed regarding these amended rules.

6. Confidential treatment is not requested.

CONCISE EXPLANATION AND ANALYSIS OF THE OPERATION, PURPOSE, AND
EFFECT OF THE RULE AMENDMENT AND ITS COMPLIANCE WITH APPLICABLE
PROVISIONS OF THE ACT, INCLUDING CORE PRINCIPLES AND THE
COMMISSION’S REGULATIONS THEREUNDER

Pursuant to Commission Rule 40.6(a)(7)(vi), the following is a concise explanation and analysis
of the operation, purpose, and effect of the amended rules. The attached amendments are
cumulative and in response to suggestions and guidance from the staff during the course of the
staff review of the GFI Swaps Exchange application for registration as a Swap Execution
Facility. These amendments are either:

(1) technical corrections to align the rules more closely with the language of Commission
Rules; and/or
(2) amendments made in response to guidance of Commission staff.

The following chart identifies the changed rules and notes the effect of the change and an
explanation of the operation, purpose, and effect of the change.




(ii) As _permitted by CFTC No-Action Letter 20-01 15-24 expiring Funes,

2046, if the Company determines that a clerical or operational error or omission was
made by the Company, one of the counterparties to a transaction or its agent, but such
operational error or omission was not discovered until after a transaction has been
cleared, the Company may permit the original counterparties to the transaction to
enter into a prearranged transaction that offsets the transaction carried on the books
of the relevant Derivatives Clearing Organization, without such transaction having to be
executed pursuant to the methods required in CFTC






CONCISE EXPLANATION AND ANALYSIS OF THE OPERATION, PURPOSE, AND
EFFECT OF THE RULE AMENDMENT AND ITS COMPLIANCE WITH APPLICABLE
PROVISIONS OF THE ACT

541(d\(H

Error Trades

rule to allow an alternative method for
correcting swaps with errors.

543(a) Post-Trade Anonymity Add rule to explain post trade anonymity

543(b) reference to CFTC final rule §37.9(d)

543(0)

601(h) Block Trades Amend text to update relief reference to
CFTC Letter No. 20-01 and date of
expiration of relief.

1001(4)(i)(ii) Cleared Swaps Amend text to update relief reference to
CFTC Letter No. 20-01 and date of
expiration of relief.

1001(d)(i) Cleared Swaps Amend text to add no-action relief from
CFTC Letter No. 20-01 to allow an
correcting swaps with alternative method
for errors.

543(a) Post-Trade Anonymity Add rule to explain post trade

543(b) anonymity reference to CFTC final

543(c)

tule §37.9(d)