360 Trading Networks, Inc. ∙ 521 Fifth Avenue, 38th Floor ∙ New York, NY 10175

360 Trading Networks, Inc.

521 Fifth Avenue, 38th Floor 

New York, NY 10175

Phone: +1 212 776 2900

Fax: +1 212 776 2902

E-Mail: info@360t.com

December 1, 2017 www.360t.com

Submitted via CFTC Portal

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Regulation 40.6(a) Rule Certification

360 Trading Networks Inc. Rulebook Amendments

Ladies and Gentlemen:

Pursuant to Section 5c(c) of the Commodity Exchange Act (the “Act”) and Section 40.6(a) of the 

Regulations of the Commodity Futures Trading Commission (the “Commission”), 360 Trading 

Networks Inc. (“360T”) hereby files the attached amendments to its Rulebook. The Rulebook 

has been amended in response to 360T business development. The amended Rulebook will 

become effective on December 15, 2017.

A concise explanation and analysis of the amendments to the Rulebook and their compliance 

with applicable provisions of the Act, including Core Principles, and the Commission’s 

Regulations thereunder, is attached hereto as Exhibit A. A clean copy of the amended Rulebook 

is attached hereto as Exhibit B, and a copy of the Rulebook marked to show changes against the 

version submitted to the Commission on August 24, 2017 is attached hereto as Exhibit C.

360T hereby certifies that: (i) the amended Rulebook complies with the Act and the 

Commission’s regulations thereunder; and (ii) a notice and copy of this submission is being 

concurrently posted on 360T’s web site. There were no substantive opposing views to the 

amendments to the Rulebook.

Please contact the undersigned at 44 020 7862 7509 or martin.oakley@360t.com if you have any 

questions or you would otherwise like to discuss this further.

Sincerely,

/s/ Martin Oakley

Chief Compliance Officer
Exhibit A

Summary: The 360T Rulebook has been amended in response to comments and questions 

received from users and potential users of 360T. A clean copy of the amended Rulebook is 

attached hereto as Exhibit B; a copy of the Rulebook marked to show changes against the version 

submitted to the Commission on August 24, 2017 is attached hereto as Exhibit C. No changes have 

been made to the User Guide for Market Takers or User Guide for Market Maker but for reference 

they are attached hereto as Exhibit D and Exhibit F respectively. 

Capitalized terms used but not defined herein have the meanings assigned to them in the Rulebook.

Amendment Explanation

Cover Page

Revised effective date

Update

Table of Contents

Revised title of Rule 517 

Update

Rule 101

Revised the definition for Authorized User

Update

Rule 311(b)

Amended language to clarify the timeframe in regards to Withdrawal of a 

Participant.

Clarification

Rule 401(a)(8)

Added language specify the books and records requirements apply to the 

Company’s Trading System.

Clarification

Rule 402(a)(2)

Added the word involuntary to specify what types of withdrawal require a 

notice.

Clarification

Rule 403

Added language to specify what type of data is stored by the Company and 

may be inspected.

Clarification

Rule 404(a)

Amended language to clarify the timeframe of Participant’s requirement to 

provide a regulatory capital report. 

Clarification

Rule 503

Amended language to clarify what acts are considered detrimental under 

Rule 503.

Clarification
2

Rule 504

Added the words “or other” to specify what transactions are covered under 

Rule 504.

Clarification

Rule 506

Amended language to say market disruptions instead of defining market 

disruption.

Clarification

Rule 512

Removed word “electronically” to specify how a client must record the time 

of a Customer Order. 

Clarification

Rule 513(a)

Changed the language from Person to individual

Clarification

Rule 513(b)

Changed the language from Person to individual

Clarification

Rule 515(b)

Changed the language from Person to individual

Clarification

Rule 517(b)

Removed Pre-Negotiated from what transactions are prohibited.

Update

Rule 526(c)(5)

Added language to specify the Company maintains sole discretion to cancel 

or adjust a trade

Clarification

Rule 527

Removed word “Finally” as the adverb isn’t needed

Update

Rule 903(c)

Added language to specify what data is on the Company’s Trading System

Clarification

Rule 904(b)(i)

Added language to specify what Participant data is in-scope for Rule 906. 

Clarification

Rule 909

Added language to specify what Swaps would be in-scope for an 

amendment, repeal or new rule.

Clarification

Rule 912(b)

Added language “in connection with the applicable Derivative Clearing 

Organization” to part (4), (5) and (6) to specify who would be carrying out 

these functions.

Clarification