December 14, 2022

Re: Updates to ICC Fee Schedules Pursuant 

to Section 5c(c)(1) of the Commodity 

Exchange Act and Commission Regulation 

40.6(a)

VIA ELECTRONIC PORTAL

Mr. Christopher Kirkpatrick

Secretary

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, D.C. 20581

Dear Mr. Kirkpatrick:

ICE Clear Credit LLC (“ICC”) hereby submits, pursuant to Section 5c(c)(1) of the Commodity Exchange Act 

(the “Act”) and Commodity Futures Trading Commission (“Commission”) Regulation 40.6(a), a selfcertification of changes to its fee schedules to implement reduced fees for credit default index swaptions 

(“Index Options”) for calendar year 2023. ICC is registered with the Commission as a derivatives clearing 

organization (“DCO”). ICC intends to implement the changes no sooner than the tenth business day 

following the filing of this submission with the Commission at its Washington, D.C. headquarters and with 

its Chicago regional office.

The proposed changes are intended to modify ICC’s fee schedules to implement reduced fees for Index 

Options for calendar year 2023.

1 This submission includes a description of the changes. Certification of the 

changes to the fee schedules pursuant to Section 5c(c)(1) of the Act and Commission Regulation 40.6(a) 

is also provided below. 

ICC maintains a Clearing Participant (“CP”) fee schedule2 and client fee schedule3(collectively, the “fee 

schedules”) that are publicly available on its website, which ICC proposes to update. Clearing fees are due 

by CPs and clients in accordance with the product, amount and currency set out in the fee schedules and 

subject to any incentive program described in the fee schedules. The proposed changes to the fee 

schedules are described in detail as follows.

The amended CP fee schedule would reduce Index Option fees to $1.5/million or €1.5/million for calendar 

year 2023. Under the regular CP fee schedule, Index Option fees are $3/million or €3/million, subject to 

an incentive program that provides a tiered discount schedule based on U.S. Dollar equivalent, non1 Pursuant to an Index Option contract, one party (the “Swaption Buyer”) has the right (but not the obligation) 

to cause the other party (the “Swaption Seller”) to enter into an index credit default swap transaction at a predetermined strike price on a specified expiration date on specified terms. In the case of Index Options that 

may be cleared by ICC, the underlying index credit default swap is limited to certain CDX and iTraxx index 

credit default swaps that are accepted for clearing by ICC, and which would be automatically cleared by ICC 

upon exercise of the Index Option by the Swaption Buyer in accordance with its terms.

2 CP fee details available at: 

https://www.theice.com/publicdocs/clear_credit/ICE_Clear_Credit_Fees_Clearing_Participant.pdf.

3 Client fee details available at: 

https://www.theice.com/publicdocs/clear_credit/ICE_Clear_Credit_Fees.pdf. As specified, all fees are 

charged directly to a client’s CP. 
discounted Index Option fees billed since the start of the year. ICC previously discounted CP Index Option 

fees for a portion of 2022, which will expire at the end of calendar year 2022.

4 Under the proposed 

changes, in addition to updating the fee table, ICC would include a footnote to indicate that the listed fees

of $1.5/million or €1.5/million are applicable from the effective date through calendar year 2023 and 

reflect a discount from ICC’s regular Index Option fees of $3/million or €3/million. The effective date 

would follow the completion of any applicable regulatory review process. 

The amended client fee schedule would reduce Index Option fees to $2/million or €2/million for calendar 

year 2023. Under the regular client fee schedule, Index Option fees are $4/million or €4/million. ICC 

previously discounted client Index Option fees for a portion of 2022, which will expire at the end of 

calendar year 2022.

5 Under the proposed changes, in addition to updating the fee table, ICC would 

indicate in a footnote that the listed fees of $2/million or €2/million are applicable from the effective date 

through calendar year 2023 and reflect a discount from ICC’s regular Index Option fees of $4/million or 

€4/million. The effective date would similarly follow the completion of any applicable regulatory review 

process.

Core Principle Review:

ICC reviewed the DCO core principles (“Core Principles”) as set forth in the Act. During this review, ICC 

identified the following Core Principle as being impacted:

Public Information: The changes to the ICC fee schedules are consistent with the public information 

requirements of Core Principle L. The fee schedules are publicly available on ICC’s website. Moreover, 

such changes to the fee schedules to temporarily reduce Index Option fees for CPs and clients would also 

be publicly available on ICC’s website and provide market participants sufficient information to enable them 

to identify and evaluate accurately the risks and costs associated with using ICC’s services. 

Amended Rules:

The proposed changes consist of updates to ICC’s fee schedules. 

Annexed as Exhibits hereto are the following:

A. Proposed changes to the CP fee schedule 

B. Proposed changes to the client fee schedule 

Certifications:

ICC hereby certifies that the fee schedule changes comply with the Act and the regulations thereunder. 

There were no substantive opposing views to the fee schedule changes.

ICC further certifies that, concurrent with this filing, a copy of the submission was posted on ICC’s website, 

and may be accessed at: https://www.theice.com/clear-credit/regulation.

ICC would be pleased to respond to any questions the Commission or the staff may have regarding this 

submission. Please direct any questions or requests for information to the attention of the undersigned at 

(312) 836-6742.

4

 A description of the 2022 CP Index Option fee discount is included in prior filing submission No. 

2201-0714-3159-09, dated February 7, 2022.

5

 A description of the 2022 client Index Option fee discount is included in prior filing submission No. 

2201-0714-3159-09, dated February 7, 2022.
Sincerely,

Eric Nield

General Counsel