ICAP GLOBAL DERIVATIVES LIMITED

Facility Rulebook

Version 3.7

June 2017

© Copyright 2016 ICAP GLOBAL DERIVATIVES LIMITED

All Rights Reserved.
FACILITY RULEBOOK

TABLE OF CONTENTS PAGE

DEFINITIONS ............................................................................................................................................... 1

CHAPTER 1 ................................................................................................................................................ 10

MARKET GOVERNANCE........................................................................................................................... 10

Rule 101 Board of Directors and Officers......................................................................................... 10

Rule 102 Limitation of Liability.......................................................................................................... 10

Rule 103 Confidentiality.................................................................................................................... 11

Rule 104 Emergency Action............................................................................................................. 12

Rule 105 Suspension of Trading ...................................................................................................... 15

Rule 106 Risk Controls for Trading .................................................................................................. 15

Rule 107 Market Data....................................................................................................................... 15

Rule 108 Intellectual Property .......................................................................................................... 16

CHAPTER 2 ................................................................................................................................................ 19

TRADING PRIVILEGES.............................................................................................................................. 19

Rule 201 Trading Privilege Holders.................................................................................................. 19

Rule 202 Authorised Traders and Authorised Trading Firms........................................................... 21

Rule 203 Financial Integrity.............................................................................................................. 23

Rule 204 Clearing............................................................................................................................. 23

Rule 205 Application for and Grant of Trading Privileges ................................................................ 27

Rule 206 Participant and Customer Obligations; Suspension or Termination of Access ................ 29

Rule 207 Customers......................................................................................................................... 30

Rule 208 Recordkeeping.................................................................................................................. 30

Rule 209 Communications of IGDL with Participants ...................................................................... 32

Rule 210 Required Disclosures to IGDL .......................................................................................... 33

Rule 211 Dues, Fees and Expenses................................................................................................ 34

Rule 212 Market Maker Programs ................................................................................................... 34

Rule 213 Independent Software Vendors ........................................................................................ 35

Rule 214 Withdrawal of Participant .................................................................................................. 35

CHAPTER 3 ................................................................................................................................................ 37

TRADING PROCEDURES.......................................................................................................................... 37

Rule 301 Trading Sessions .............................................................................................................. 37

Rule 302 Information about, and access to, IGDL’s Order Book ..................................................... 37

Rule 303 Required Transactions...................................................................................................... 37

Rule 304 Permitted Transactions ..................................................................................................... 38

Rule 305 Execution Methods for Required Transactions................................................................. 38

Rule 306 Work Up ............................................................................................................................ 41

Rule 307 Acceptable Bids and Offers .............................................................................................. 41

Rule 308 Block Trades ..................................................................................................................... 41

Rule 309 Reporting and Data Collection .......................................................................................... 42

Rule 310 Bid/Offer Cancellation ....................................................................................................... 44

Rule 311 [Reserved]......................................................................................................................... 44

Rule 312 Enforceability of Transactions........................................................................................... 45

Rule 313 Intermediated Transactions .............................................................................................. 46

Rule 314 Bunched Orders ................................................................................................................ 46

Rule 315 IGDL Authority over Transactions..................................................................................... 47

Rule 316 Reporting Counterparty..................................................................................................... 52

CHAPTER 4 ................................................................................................................................................ 53

TRADING STANDARDS............................................................................................................................. 53

Rule 401 Fraudulent Statements and Acts....................................................................................... 53

Rule 402 Abusive Trading Practices ................................................................................................ 53

Rule 403 Good Faith Bids/Offers and RFQs .................................................................................... 53

Rule 404 Pre-Execution Discussions and Pre-Arranged Transactions............................................ 53

Rule 405 Manipulation and Price Distortion ..................................................................................... 54
ii

Rule 406 Disruptive Trading Practices ............................................................................................. 54

Rule 407 General Offences.............................................................................................................. 55

Rule 408 Position Limits and Position Accountability....................................................................... 55

CHAPTER 5 ................................................................................................................................................ 57

RULE ENFORCEMENT.............................................................................................................................. 57

Rule 501 Jurisdiction ........................................................................................................................ 57

Rule 502 Facility Market Regulation Staff Powers and Duties......................................................... 57

Rule 503 The Review Panel............................................................................................................. 58

Rule 504 Notice of Charges ............................................................................................................. 59

Rule 505 Answer; Request for Hearing; Failure to Answer or Deny Charges ................................. 59

Rule 506 Selection of Hearing Panel ............................................................................................... 60

Rule 507 Challenge to Members of the Hearing Panel.................................................................... 60

Rule 508 Hearing on Sanctions in the Event of Failure to Deny Charges; Failure to 

Request Hearing Deemed Acceptance of Sanctions........................................................ 60

Rule 509 Settlement Prior to Commencement of Hearing ............................................................... 61

Rule 510 Hearing Procedures .......................................................................................................... 61

Rule 511 Written Decision of Hearing Panel .................................................................................... 63

Rule 512 Liability for Expenses ........................................................................................................ 64

Rule 513 Effective Date of Sanctions............................................................................................... 64

Rule 514 Summary Suspension....................................................................................................... 64

Rule 515 Extension of Time Limits................................................................................................... 65

Rule 516 Summary Fines ................................................................................................................. 65

CHAPTER 6 ................................................................................................................................................ 67

CONTRACTS TO BE TRADED .................................................................................................................. 67

Rule 601 Listing Procedures ............................................................................................................ 67

Rule 602 Swaps Not Readily Susceptible to Manipulation .............................................................. 67

CHAPTER 7 ................................................................................................................................................ 68

GOVERNING LAW, JURISDICTION AND DISPUTE RESOLUTION ........................................................ 68

Rule 701 Choice of Law ................................................................................................................... 68

Rule 702 Disputes Among Trading Privilege Holders, Authorised Traders, Authorised 

Trading Firms and Customers .......................................................................................... 68

Rule 703 Disputes with IGDL ........................................................................................................... 68

CHAPTER 8 ................................................................................................................................................ 69

CONTRACT SPECIFICATIONS................................................................................................................. 69

Rule 801 Interest Rate Swaps Products Descriptions ..................................................................... 69

CHAPTER 9 ................................................................................................................................................ 93

SYSTEM PROTOCOLS.............................................................................................................................. 93

Rule 901 iSwap System Protocol .......................................................................................................... 93

Rule 902 Voice RFQ System Protocol ................................................................................................ 102
DEFINITIONS

Except where the context requires otherwise, the following terms shall have the following meanings when 

used in the Rules. Use of the singular shall include the plural and vice versa, unless the context requires 

otherwise.

Act means the U.S. Commodity Exchange Act, as amended from time to time.

Affiliate means, with respect to any person, any other person who controls, is controlled by or is under 

common control with such person.

Affirm means the process by which the counterparties to a Cleared Contract verify that they agree on the 

details of the transaction after execution on the Facility but prior to submission to the relevant DCO, which 

may be done by any means acceptable to the counterparties, including the use of an Affirmation Hub, and 

“Affirmations” shall be construed accordingly.

Affirmation Hub means a third-party service designated by IGDL to route Cleared Contracts to DCOs 

and which may provide Participants with the opportunity to Affirm the Cleared Contracts.

Answer shall have the meaning set forth in Rule 505.

Applicable Law means, with respect to any person, any statute, law, regulation, rule or ordinance of any 

Governmental Authority applicable to such person, including but not limited to the FCA’s rules, the Act 

and Commission Regulations.

Appropriate Minimum Block Size shall have the meaning set forth in Rule 308.

Authorised Trader means an individual designated as such by, and acting on behalf of, a Trading 

Privilege Holder to enter Bids/Offers, issue and respond to RFQs, submit Pre-Arranged Crosses, access 

a Trading Platform and execute transactions in Contracts.

Authorised Trading Firm means an entity designated as such by a Trading Privilege Holder to enter 

Bids/Offers, issue and respond to RFQs, submit Pre-Arranged Crosses, access a Trading Platform and 

execute transactions in Contracts either as an Intermediary for such Trading Privilege Holder or as a 

Customer with DMA granted by such Trading Privilege Holder.

BASIC shall have the meaning set forth in Rule 205(f).

Bid/Offer means a bid or offer entered into a Trading Platform operated by IGDL or submitted to the 

Facility in response to an RFQ.

Block Trade means a Swap transaction that is publicly reportable under Part 43 of the Commission 

Regulations that:

(a) Involves a Swap that is listed on the Facility;

(b) Occurs away from the Facility and is executed pursuant to Rule 308;

(c) Has a notional or principal amount at or above the Appropriate Minimum Block Size; and

(d) Is reported to the Facility as provided in Rule 308.

Board means the Board of Directors of IGDL.
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Breakage Agreement means an agreement or any other arrangement between the parties that provides 

for the assessment of liability or payment of damages between the parties to a Cleared Contract in the 

event that the Cleared Contract is rejected from clearing.

Business Day means any day on which a Contract is available for trading on the Facility.

Call Option means an Option whereby (i) the purchaser has the right, but not the obligation, to buy an 

Underlying Interest, at the strike price specified; and (ii) the grantor has the obligation, upon exercise, to 

enter into an Underlying Interest for delivery in such Delivery Month, at such strike price.

CF10 means the head of Compliance and Oversight (Controlled Function 10), or one duly authorised to 

act with the authority of the CF10.

Chairman of the Board means the chairman of the Board.

Chief Compliance Officer means the chief compliance officer of IGDL, or one duly authorised to act with 

the authority of the Chief Compliance Officer.

Chief Executive Officer means the Chief Executive Officer of IGDL, or one duly authorised to act with 

the authority of such officer.

Class means, with respect to any Swap, a Contract covering the same Underlying Interest.

Cleared Contract means any Contract that is listed for clearing by IGDL.

Clearing Firm means a clearing member of a DCO that is authorised pursuant to the rules of such DCO 

to clear transactions in any or all Contracts.

Clearing Firm Representation shall have the meaning set forth in Rule 204(f).

Cleared Treasury Security means any U.S. Treasury Security cleared through the Fixed Income 

Clearing Corporation.

CME means Chicago Mercantile Exchange Inc.

Commission means the U.S. Commodity Futures Trading Commission or any successor regulatory 

body.

Commission Regulations means any rule, regulation, order, directive and any interpretation thereof 

promulgated by the Commission, as amended.

Commodity shall have the same meaning as in the Act.

Commodity Interest shall have the meaning set forth in Commission Regulation 1.3.

Compliance Function means the Chief Compliance Officer and CF10 together.

Confirmation shall have the same meaning as in Commission Regulation 45.1.

Confidential Information means all non-public information that is stated to be or that can reasonably 

expected to be of a confidential or trade secret nature in any form obtained by a Participant from IGDL in 

accessing or using the Systems, including, but not limited to, any processes, or proprietary data, 

information or documents regarding the Systems, save to the extent that such information: (i) is already 

in the public domain at the time of disclosure; (ii) enters the public domain other than by a breach of any 

obligation of confidentiality; (iii) is required to be disclosed by reason of Applicable Law, provided that, 
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where permitted by Applicable Law, prior notice of such disclosure shall be provided to IGDL as soon as 

practicable in order to permit IGDL to seek a protective order or take other appropriate action to 

safeguard the Confidential Information; or (iv) is permitted to be disclosed pursuant to the Rules.

Contract means any Swap listed for trading on the Facility.

Covered Package Transaction means a “MAT/Non-MAT Uncleared Package Transaction,” a 

“MAT/Non-Swap Instruments Package Transaction,” and a “MAT/Non-CFTC Swap Package 

Transaction,” each as defined in NAL 16-76, expiring November 15, 2017.

Customer means any person (including another Trading Privilege Holder), or such person’s agent with 

the legal ability to direct trading on behalf of such person, that transacts on the Facility through a 

Participant acting as an Intermediary.

Customer Type Indicator Codes shall have the meaning set forth in Rule 208.

DCO means, with respect to any Swap, a derivatives clearing organisation authorised to clear such 

Swap.

Delivery Month means, with respect to any Contract, the month in which delivery of an Underlying 

Interest is to be made pursuant to the terms of such Contract.

Derived Information means Information that has been altered, enhanced, modified or from which 

derivative information has been created.

Director means a member of the Board.

Directed Voice RFQ means a voice RFQ conducted in accordance with Rule 305(c)(2).

DMA means a Trading Privilege Holder (including an Intermediary) permitting a Customer to transmit 

orders electronically to the Trading Privilege Holder’s systems for onward transmission to a Trading 

Platform utilising the Trading Privilege Holder’s trading identification.

DTCC means DTCC Data Repository (U.S.) LLC.

Eligible Counterparty has the meaning given in the FCA Handbook.

Emergency shall have the meaning set forth in Rule 104.

Erroneously Cleared Transactions shall have the meaning set forth in Rule 315(i).

Error shall have the meaning set forth in Rule 315(h).

Expiration Day means the day on which an Option expires.

Execution Specialist means any personnel of IGDL responsible for assisting Participants with entering 

Bids/Offers in the Order Book, issuing and responding to RFQs, executing and receiving reports of Block 

Trades and executing Pre-Arranged Crosses.

Facility means the venue provided by IGDL for the execution of Contracts, as set out in this Facility 

Rulebook.

Facility Subject Person means any person that has consented to the jurisdiction of the Facility and 

agreed to be bound by and comply with the Rules pursuant to Rule 201(e).
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FCA means the Financial Conduct Authority.

FICC Clearing Member means a clearing member of the Fixed Income Clearing Corporation’s 

Government Securities Division.

FICC Clearing Member Representation shall have the meaning set forth in Rule 204(j).

Financial Entity has the meaning set forth in the Act.

Governance Policy means the Governance Policy of IGDL available on the Facility’s website.

Governmental Authority means any domestic or foreign government (or political subdivision), 

governmental or regulatory authority, agency, court, commission or other governmental or regulatory 

entity (including any self-regulatory association).

Hearing Date shall have the meaning set forth in Rule 506.

Hearing Panel shall have the meaning set forth in the Governance Policy.

Hearing Panel Chairman shall have the meaning set forth in Rule 506.

Hearing Record shall have the meaning set forth in Rule 510.

Held Order means a firm executable Order placed for entry onto the Order Book.

ID shall have the meaning set forth in Rule 302.

ICAP means ICAP plc and its Affiliates.

IGDL means ICAP Global Derivatives Limited (Company Number: 03635229).

IGDL Indemnified Party shall have the meaning set forth in Rule 108(f).

Implied Package Transaction means a transaction executed on or subject to the Rules involving two or 

more instruments that is quoted as one economic transaction with simultaneous or near simultaneous 

execution of all components, but where the execution of each component is not contingent upon the 

execution of all other components and where any Participant or Customer may submit a Bid/Offer for less 

than all of the components of the transaction.

Indemnified Party shall have the meaning set forth in Rule 108(f).

Indemnifying Party shall have the meaning set forth in Rule 108(f).

Information shall have the meaning set forth in Rule 107.

Intellectual Property Rights means all right, title and interest in and to (i) trademarks, service marks, 

brand names and other indications of origin and the goodwill associated with the foregoing; (ii) inventions, 

patents, trade secrets, know-how, processes and systems; (iii) copyright and database rights; and (iv) any 

other intellectual property or similar proprietary rights in any jurisdiction, in each case whether registrable 

or not.

Intermediary means any person that enters Bids/Offers into a Trading Platform, issues and responds to 

RFQs, reports block trades or submits Pre-Arranged Crosses to the Facility on behalf of Customers, 

including without limitation, any futures commission merchant, introducing broker or commodity trading 

adviser registered with the Commission.
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Intermediated Transaction means any transaction on the Facility conducted through an Intermediary.

ISDA means the International Swaps and Derivatives Association, Inc.

ISDA Reporting Party Rules means the reporting party rules set forth in the document published by 

ISDA entitled “Dodd Frank Act – Swap Transaction Reporting Party Requirements” dated July 15, 2013, 

as set forth in Annex 1.

JSCC means Japan Securities Clearing Corporation.

Last Trading Day means, with respect to any Swap, the last day on which trading is permitted for such 

Swap in accordance with the Rules.

Legal Entity Identifier or LEI shall have the same meaning as in Commission Regulations.

Losses shall have the meaning set forth in Rule 102(a).

Major Swap Participant shall have the same meaning as in the Act and Commission Regulations.

Managed Order shall have the meaning set forth in Rule 305(c)(4).

Market Regulation Staff means the personnel designated by IGDL as members of the Market 

Regulation Staff, any agents of IGDL that assist in the implementation, surveillance, and enforcement of 

its rules and related obligations, and IGDL’s Regulatory Services Provider.

MiFID means the Markets in Financial Instruments Directive 2004/39/EC.

MTF means multilateral trade facility, as defined in the FCA Handbook.

NAL means Commission No-Action Letter.

NFA means the National Futures Association.

Non-Cleared Contract means a Contract that is not a Cleared Contract.

Non-Directed Voice RFQ means a voice RFQ conducted in accordance with Rule 305(c)(1).

Non-Reviewable Range means the amounts that are above and below the fair market value for each 

Contract or Contract type, as set forth in Rule 315.

Notice shall have the meaning set forth in Rule 504.

Option means a Swap whereby one party grants to another the right, but not the obligation, to buy or sell 

a Commodity or other Underlying Interest.

Order means an instruction by a Customer to a Participant to execute a transaction on behalf of such 

Customer.

Order Book means a Trading Platform in which all Trading Privilege Holders have the ability to enter, 

observe and transact on multiple Bids/Offers.

Package Transaction means a transaction executed on the Facility or subject to the Rules involving two 

or more instruments: (i) that is executed between two or more parties that are Participants or Customers; 

(ii) that is priced or quoted as one economic transaction with simultaneous or near simultaneous 

execution of all components; (iii) that has at least one component that is a Swap that has been made 
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available to trade pursuant to section 2(h)(8) of the Act; and (iv) where the execution of each component 

is contingent upon the execution of all other components.

Participant means any Trading Privilege Holder, Authorised Trader or Authorised Trading Firm.

Participant Indemnified Party shall have the meaning set forth in Rule 108(f).

Participation Committee shall have the meaning set forth in the Governance Policy.

Permitted Transaction means any transaction involving a Swap that is not subject to the trade execution 

requirement in section 2(h)(8) of the Act.

person means any individual, sole proprietorship, corporation, limited liability company, limited liability 

partnership, partnership, association, estate, trust, governmental agency, unincorporated organisation or 

any other legal entity.

Physical Emergency shall have the meaning set forth in Rule 104.

Position Limit means the maximum position, either net long or net short, in one Series or a combination 

of various Series of a particular Class that may be held or controlled by one person, or subject to 

aggregation with such person’s position, as prescribed by IGDL and/or Commission.

Pre-Arranged Cross means a Permitted Transaction pre-arranged pursuant to Rule 304(b).

Proceeding shall have the meaning set forth in Rule 108(f).

Proprietary Data and Personal Information means data and information that separately discloses 

business transactions, market positions or trade secrets of a person with respect to that person, but 

excludes information in a Confirmation or Trade Communication that discloses the identity of another 

person.

Public Director means any person who qualifies as a “public director” within the meaning set forth in the 

Commission Regulations.

Put Option means an Option whereby (i) the purchaser has the right, but not the obligation, to sell an 

Underlying Interest at the strike price specified; and (ii) the grantor has the obligation, upon exercise, to 

buy an Underlying Interest at such strike price.

Recipient means a Participant who is a recipient of an RFQ.

Regulatory Agency means any Governmental Authority, including the FCA, the Commission and the 

U.S. Securities and Exchange Commission (“SEC”), the NFA and any other SRO, and any organisation, 

whether domestic or foreign, granted authority under statutory or regulatory provisions to regulate its own 

activities and the activities of its members, not including IGDL.

Regulatory Oversight Committee shall have the meaning set forth in the Governance Policy.

Regulatory Services Provider means an outside organisation which provides regulatory services to 

IGDL pursuant to an agreement.

Rejected Leg shall have the meaning set forth in Rule 315(i).

Rejected Transactions shall have the meaning set forth in Rule 315(i).

Related Parties shall have the meaning set forth in Rule 107.
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Request for Quote or RFQ means a request by one Participant to at least such minimum number of 

Participants as may be required by Commission Regulations from time to time for a market quote that 

shall constitute a Bid/Offer.

Required Transaction means any transaction involving a Swap that is subject to the trade execution 

requirement in section 2(h)(8) of the Act.

Respondent shall have the meaning set forth in Rule 504(a).

Review Panel shall have the meaning set forth in the Governance Policy.

Risk-Based Limits means the risk-based limits established by a Clearing Firm in accordance with 

Commission Regulation 1.73.

Rule or Rules means the rules, resolutions, interpretations, statements of policy, decisions, directives 

and orders of the Facility (including this Rulebook).

Secretary means the individual appointed by the Board from time to time to serve as secretary of IGDL.

SEF means swap execution facility, as defined in the Act.

Series means all Contracts of the same Class having identical terms.

SRO means self-regulatory organisation.

Swap shall have the same meaning as in the Act and Commission Regulations. Swap Data Repository

or SDR shall have the same meaning as in the Act.

Swap Dealer shall have the same meaning as in the Act and Commission Regulations.

Systems means the Trading Platforms, including various proprietary and third party software, firmware, 

hardware, keypads and supporting documentation to which Participants are granted access by IGDL.

System Protocol means the terms from time to time in force upon which a Participant may access a 

specific Trading Platform, including any supplemental written guidelines provided by IGDL to the 

Participant, as amended from time to time. The System Protocols shall be posted on the Facility’s 

website. In the event of any inconsistency between the provisions of any System Protocol and the Rules, 

the terms of the System Protocol shall prevail.

Terms Incorporated by Reference shall have the meaning set forth in Rule 312.

Trade Communication shall have the meaning set forth in Rule 312.

Trading Platform means any of the separate electronic central limit order books and other systems 

administered by or on behalf of IGDL for the trading of Contracts pursuant to specific System Protocols 

for each such system.

Trading Privilege Holder means an individual or entity with Trading Privileges on the Facility granted 

pursuant to Rule 201 (including an Intermediary), but does not include an Authorised Trading Firm or 

Authorised Trader.

Trading Privileges means permission from IGDL given to any Trading Privilege Holder in accordance 

with Rule 201 to access the Facility, or to any Authorised Trading Firm or Authorised Trader in 

accordance with Rule 202 to access the Facility.
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Trading Session means, with respect to any Contract, the period of hours on any Business Day during 

which such Contract is available for trading, as specified in the Rules governing such Contract.

Underlying Interest means the interest which is the subject of a Swap.

U.S. Dollar Swap Spread means a Package Transaction in which each of the Swap components has 

been made available to trade by IGDL pursuant to section 2(h)(8) of the Act and all other components are 

U.S. Treasury Securities.

U.S. Treasury Security means a bond, note, bill or other evidence of indebtedness issued by the United 

States Treasury.

Violation means a violation of any of the Rules.
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GENERAL

Regulatory Status

United Kingdom and the EEA

ICAP Global Derivatives Limited (FRN 191757) is regulated by the FCA and is authorised, among other 

things, to:

• arrange (bring about) deals in investments

• deal in investments as agent;

• make arrangements with a view to transactions in investments; and

• operate a MTF (as set in the relevant System Protocol).

IGDL has passporting rights under MiFID in relation to certain of its permissions.

United States of America

IGDL is registered as a SEF with the Commission.

Compliance Oversight

The Chief Compliance Officer and the Head of Compliance and Oversight (CF10), both appointed by the 

Board, assist IGDL in meeting its regulatory obligations, as set out by the Commission and the FCA 

respectively.

References in this Facility Rulebook and any other related document to the Compliance Function is 

intended to mean, for Commission related considerations, the Chief Compliance Officer and, for FCA 

related considerations, the CF10. To the extent any of the activities concern both the Commission and 

FCA, the Chief Compliance Officer and the CF10 will cooperate to ensure compliance with the respective 

regulations.
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CHAPTER 1

MARKET GOVERNANCE

Rule 101 Board of Directors and Officers

(a) Management. The Board manages, operates and sets policies, including the Governance Policy, 

for IGDL and the Facility. The Board has the power to appoint such officers of IGDL as it may deem 

necessary or appropriate from time to time.

(b) Governance Policy. The Governance Policy shall be deemed to be part of the Rules, and shall 

be deemed to be incorporated herein, to the same extent and with the same force and effect as if set forth 

herein in their entirety.

Rule 102 Limitation of Liability

(a) TO THE EXTENT PERMITTED BY APPLICABLE LAW, AND EXCEPT FOR PRIVATE RIGHTS 

OF ACTION UNDER SECTION 22(B) OF THE ACT OR IN INSTANCES WHERE AN ICAP PARTY (AS 

DEFINED BELOW) HAS BEEN FINALLY ADJUDICATED TO HAVE ENGAGED IN NEGLIGENCE, 

WILFUL DEFAULT OR FRAUD, IGDL (INCLUDING ITS RESPECTIVE SUBSIDIARIES AND 

AFFILIATES) AND THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, 

CONSULTANTS AND LICENSORS (EACH, AN “ICAP PARTY”), SHALL NOT BE LIABLE TO ANY 

PERSON FOR ANY LOSSES, DAMAGES, COSTS OR EXPENSES (INCLUDING, BUT NOT LIMITED 

TO, LOSS OF PROFITS, LOSS OF USE, AND DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL 

OR PUNITIVE DAMAGES) IN CONTRACT, TORT, OR OTHERWISE AND WHETHER THE CLAIM IS 

BROUGHT DIRECTLY OR AS A THIRD PARTY CLAIM, ARISING FROM:

(1) ANY FAILURE, MALFUNCTION, FAULT IN DELIVERY, DELAY, OMISSION,

SUSPENSION, INACCURACY, INTERRUPTION, TERMINATION, OR ANY OTHER 

CAUSE, IN CONNECTION WITH THE FURNISHING, PERFORMANCE, OPERATION, 

MAINTENANCE, USE OF OR INABILITY TO USE ALL OR ANY PART OF ANY OF THE 

SYSTEMS AND SERVICES OF IGDL OR ANY ICAP PARTY, OR SERVICES, 

EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH SYSTEMS AND SERVICES, 

INCLUDING WITHOUT LIMITATION ELECTRONIC ORDER ENTRY/DELIVERY, 

TRADING THROUGH ANY ELECTRONIC MEANS, ELECTRONIC COMMUNICATION 

OF MARKET DATA OR INFORMATION, WORKSTATIONS USED BY PARTICIPANTS, 

PRICE REPORTING SYSTEMS AND ANY AND ALL TERMINALS, COMMUNICATIONS 

NETWORKS, CENTRAL COMPUTERS, SOFTWARE, HARDWARE, FIRMWARE AND 

PRINTERS RELATING THERETO; OR

(2) ANY FAILURE OR MALFUNCTION, FAULT IN DELIVERY, DELAY, OMISSION, 

SUSPENSION, INACCURACY, INTERRUPTION OR TERMINATION, OR ANY OTHER 

CAUSE, OF ANY SYSTEM OR SERVICE OF IGDL OR ANY ICAP PARTY, OR 

SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH SYSTEMS OR 

SERVICES, CAUSED BY ANY THIRD PARTIES INCLUDING, BUT NOT LIMITED TO, 

INDEPENDENT SOFTWARE VENDORS AND NETWORK PROVIDERS; OR

(3) ANY ERRORS OR INACCURACIES IN INFORMATION PROVIDED BY IGDL OR ANY 

ICAP PARTY OR ANY OF IGDL’S OR ICAP PARTY’S SYSTEMS, SERVICES OR 

FACILITIES; EXCEPT FOR INCORRECT ORDER STATUS; OR

(4) ANY UNAUTHORISED ACCESS TO OR UNAUTHORISED USE OF ANY OF IGDL’S 

OR ICAP PARTY’S SYSTEMS, SERVICES OR FACILITIES BY ANY PERSON.
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(b) NO EXPRESS OR IMPLIED WARRANTIES OR REPRESENTATIONS (INCLUDING BUT NOT 

LIMITED TO WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE 

OR USE) ARE PROVIDED BY IGDL OR ANY ICAP PARTY, THEIR RESPECTIVE OFFICERS, 

DIRECTORS, EMPLOYEES, AGENTS, CONSULTANTS, OR LICENSORS RELATING TO ANY 

SYSTEMS OR SERVICES OF IGDL OR ICAP PARTY OR SERVICES, EQUIPMENT OR FACILITIES 

USED TO SUPPORT SUCH SYSTEMS OR SERVICES, INCLUDING A TRADING PLATFORM, WHICH 

ARE PROVIDED “AS IS” TO PARTICIPANTS. NEITHER IGDL NOR ICAP MAKE ANY 

REPRESENTATIONS OR WARRANTIES, EXPRESS OR IMPLIED THAT ANY SYSTEMS OR 

SERVICES OF IGDL OR ICAP (INCLUDING EACH OF THEIR RESPECTIVE SUBSIDIARIES AND 

AFFILIATES) OR SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH SYSTEMS OR 

SERVICES, INCLUDING A TRADING PLATFORM, WILL MEET A PARTICIPANT’S REQUIREMENTS, 

HAVE UNINTERRUPTED OR ERROR-FREE OPERATION, BE AVAILABLE DURING ANY SPECIFIED 

BUSINESS HOURS (WHETHER ADVERTISED OR NOT) OR OPERATE IN CONJUNCTION WITH 

OTHER SOFTWARE.

(c) ANY DISPUTE ARISING OUT OF THE USE OF SYSTEMS OR SERVICES OF IGDL OR ANY 

ICAP PARTY OR SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH SYSTEMS OR 

SERVICES IN WHICH IGDL OR AN ICAP PARTY IS A PARTY MUST BE BROUGHT WITHIN ONE 

YEAR FROM THE TIME THAT A CAUSE OF ACTION HAS ACCRUED. ANY SUCH DISPUTE MAY 

ONLY BE LITIGATED SUBJECT TO THE RULES OF THIS RULEBOOK AND WILL BE GOVERNED BY 

THE LAWS SET OUT IN THIS RULEBOOK.

(d) EXCEPT IN INSTANCES WHERE AN ICAP PARTY HAS BEEN FINALLY ADJUDICATED TO 

HAVE ENGAGED IN NEGLIGENCE, WILLFUL DEFAULT OR FRAUD, IN NO EVENT SHALL THE ICAP 

PARTIES’ TOTAL COMBINED AGGREGATE LIABILITY FOR ALL CLAIMS ARISING OUT OF ANY 

NEGLIGENCE, FAILURES, MALFUNCTIONS, FAULTS IN DELIVERY, DELAYS, OMISSIONS, 

SUSPENSIONS, INACCURACIES, INTERRUPTIONS, TERMINATIONS, ORDER STATUS ERRORS 

OR ANY OTHER CAUSES, IN CONNECTION WITH THE FURNISHING, PERFORMANCE, 

OPERATION, MAINTENANCE, USE OF OR INABILITY TO USE ALL OR ANY PART OF ANY OF 

IGDL’S OR AN ICAP PARTY’S SYSTEMS OR SERVICES, OR SERVICES, EQUIPMENT OR 

FACILITIES USED TO SUPPORT SUCH SYSTEMS AND SERVICES, OR THE NEGLIGENCE OF IGDL 

OR AN ICAP PARTY STAFF, EXCEED $50,000 FOR ALL LOSSES FROM ALL CAUSES SUFFERED 

BY ALL PERSONS ON A SINGLE DAY; $200,000 FOR ALL LOSSES SUFFERED BY ALL PERSONS 

FROM ALL CAUSES IN A SINGLE CALENDAR MONTH; AND $500,000 FOR ALL LOSSES FROM ALL 

CAUSES SUFFERED BY ALL PERSONS IN A SINGLE CALENDAR YEAR.

(e) A CLAIM AGAINST IGDL OR AN ICAP PARTY, ARISING OUT OF ANY FAILURE OR 

MALFUNCTION SHALL ONLY BE ALLOWED IF SUCH CLAIM IS BROUGHT IN ACCORDANCE WITH 

THIS RULE.

(f) NOTWITHSTANDING THE FOREGOING, THE LIMITATION OF LIABILITY PURSUANT TO 

THIS RULE 102 IS LIMITED TO CLAIMS ARISING OUT OF IGDL’S AND AN ICAP PARTY’S 

OPERATION OF THE FACILITY AND/OR PROVISION OF SERVICES TO IGDL.

Rule 103 Confidentiality

(a) IGDL shall not, and shall cause its Affiliates not to, use for business or marketing purposes any 

Proprietary Data or Personal Information it or any of its Affiliates collects or receives, from or on behalf of 

any person, for the purpose of fulfilling IGDL’s regulatory obligations, unless the person who provided 

such data or information provides prior written consent to IGDL’s use of such data or information for such 

purposes. In furtherance of Applicable Law, IGDL may share such data and information with its Affiliates, 

the Commission, the FCA, one or more SEFs, SDRs, DCOs or Designated Contract Markets registered 

with the Commission, and, to the extent permitted by Applicable Law, other Governmental Authorities, 

including those in countries outside the U.S. and U.K. IGDL may, upon request of a Trading Privilege 

Holder, provide a list of current Trading Privilege Holders on a confidential basis. The receiving Trading 

Privilege Holder shall not disclose the contents of the list without the prior consent of IGDL. Proprietary 
12

Data and Personal Information shall not include aggregated price and volume information not identified 

with a specific Participant or Customer, and IGDL may use such aggregated information for business and 

marketing purposes.

(b) No IGDL employee shall trade, directly or indirectly, in any:

(1) Contract;

(2) Commodity Interest related to a Contract;

(3) Commodity Interest traded on designated contract markets or SEFs or cleared by DCOs 

if the employee has access to material, non-public information concerning such 

Commodity Interest; or

(4) Commodity Interest traded on or cleared by a linked exchange if the employee has 

access to material, non-public information concerning such Commodity Interest.

(c) No IGDL Affiliate, member of the Board or any committee established by the Board or by or 

pursuant to the Rules of the Facility, or any officer or other employee or consultant of IGDL, shall, either 

during or after service with IGDL:

(1) trade for such person’s own account, or for or on behalf of any other account, in any

Commodity Interest, on the basis of any material, non-public information obtained 

through special access related to the performance of such person’s official duties; or

(2) absent prior written consent of IGDL, use, directly or indirectly, information that is

deemed to be non-public information, or disclose non-public information to others, except 

(i) to others within IGDL, IGDL’s Affiliates or to outside advisers thereof or other service 

providers for IGDL, provided that such advisors and service providers are subject to 

confidentiality obligations, and that, in each case, such disclosure is necessary for the 

performance of Facility-related duties by the individual or entity, (ii) if required by a 

Regulatory Agency, or (iii) if compelled to do so by valid legal process, provided that the 

individual or entity notifies IGDL in advance thereof to the extent permitted.

(d) Subject to Rule 103(a), IGDL shall not, except as reasonably necessary to operate any Trading 

Platform, to fulfil its obligations under this Rulebook or to comply with Applicable Law or any request of 

the Commission or the FCA, without the prior written consent of a Trading Privilege Holder in each 

instance, (i) use in advertising, publicity, marketing or other promotional materials, the name, trade name, 

trademark, trade device, service mark or symbol of such Trading Privilege Holder or any of its Affiliates, or 

(ii) represent that any product or any service provided by IGDL has been approved or endorsed by such 

Trading Privilege Holder or any of its Affiliates.

(e) For purposes of this Rule 103, the terms “employee”, “material information” and “non-public 

information” have the meanings ascribed to them in Commission Regulation § 1.59.

Rule 104 Emergency Action

(a) Definitions. As used in this section:

The term “Emergency” shall mean any occurrence or circumstance which, in the opinion of IGDL, 

requires immediate action and threatens or may threaten such things as the fair and orderly trading in, or 

the liquidation of, or delivery pursuant to, any Contracts on the Facility, including any manipulative or 

attempted manipulative activity; any actual, attempted, or threatened corner, squeeze, congestion, or 

undue concentration of positions; any circumstances which may materially affect the performance of 

Contracts traded on the Facility, including failure of the payment system or the bankruptcy or insolvency 
13

of any Participant; any action taken by any Governmental Authority, or any other board of trade, swap 

execution facility, market or facility which may have a direct impact on trading on the Facility and any 

other circumstance which may have a severe, adverse effect upon the functioning of the Facility.

(b) Emergency action may be taken by the following:

(1) By the Board in the case of any Emergency;

(2) By any two members of the Board in the case of any Emergency where it is impracticable 

in the opinion of the Chairman of the Board or in his or her absence, any 

two (2) members of the Board, to call a meeting of the Board to deal with the Emergency; 

or

(3) By any committee of IGDL pursuant to powers conferred on said committee under the 

Rules or by the Board.

(c) Vote Required

The vote required of the Board or committee authorised to take any Emergency action hereunder shall 

be:

(1) In the case of action by the Board, the affirmative vote of a majority of the members of 

the Board present and voting at a meeting at which there is a quorum; or

(2) In the case of action by a committee, the affirmative vote of two (2) or more persons 

constituting not less than a majority of the members of said committee present and voting 

at a meeting at which there is a quorum.

The consent in writing to any Emergency action of all members of the Board or of a committee, as 

applicable, shall be sufficient to take such Emergency action without a meeting. A member of the Board 

or of a committee shall be deemed present or in attendance at a meeting if such a person participates in 

the meeting by means of a conference telephone or similar communications equipment allowing all 

persons participating in the meeting to hear each other at the same time.

(d) Action which may be taken

(1) In the event of an Emergency, IGDL may, subject to Part 40 of the Commission 

Regulations under the Act, place into immediate effect a Rule which may provide for, or 

may authorise IGDL, or any committee, to undertake actions which, in the opinion of 

IGDL are necessary or appropriate to meet the Emergency, including, but not limited to, 

such actions as:

(i) Extending or shortening the expiration date for trading in Contracts;

(ii) Extending the time of delivery under or expiration of Contracts;

(iii) Extending, limiting or changing hours of Trading Sessions;

(iv) Imposing or modifying price limits;

(v) Imposing or modifying Position Limits;

(vi) Imposing or modifying intraday market restrictions;

(vii) Ordering the liquidation or transfer of open positions in any Contract;
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(viii) Ordering the establishment of a settlement price;

(ix) Suspending trading pursuant to Rule 105 or curtailing trading in any Contract;

(x) Cancel any Bid/Offer;

(xi) Altering any Contract’s settlement terms or conditions prior to execution and 

adjusting or cancelling any executed transaction pursuant to Rule 315; and

(xii) Modifying or suspending any provision of the Rules.

(2) In the event of an Emergency when a quorum of the Board is not available, all trading on

the Facility may be suspended by an affirmative vote of a majority of the Directors 

present, or by action of one Director if only one Director is present, for such period of time 

as in their or his or her judgment is necessary. In the event of an Emergency which 

prevents normal attendance at a meeting of the Board, when no Director is present, any 

authorised officer of IGDL shall have authority to order suspension of trading on the 

Facility for such period of time as in his or her judgment is necessary. Any action taken 

under this paragraph (b) shall be subject to review and modification by the Board.

(3) Whenever any action is taken under this Rule pursuant to which trading is suspended or 

other changes in procedure are made, all matters relating to notices, deliveries and other 

obligations may be suspended or deferred in such manner as the Board or committee, as 

the case may be, may determine.

(4) IGDL may be required to take an Emergency action when directed by the FCA or the 

Commission. If a Contract is traded both on the Facility and on one or more other swap 

execution facilities, any Emergency action to liquidate or transfer of open positions in any 

Contract will be made in consultation with the Commission or Commission staff.

(e) Physical Emergencies

(1) In the event the physical functions of the Facility or IGDL are, or are threatened to be, 

severely and adversely affected by a physical emergency, such as fire or other casualty, 

bomb threat, substantial inclement weather, power failure, communication or 

transportation breakdown, computer malfunction, screen-based Trading Platform 

break-down, malfunction of plumbing, heating, ventilation and air conditioning systems, 

backlog or delay in clearing or in the processing of data related to clearing Cleared 

Contracts (a “Physical Emergency”), the Chairman of the Board, or in his or her 

absence the Chief Executive Officer, or in both of their absences any other authorised 

officer may take any action which, in the opinion of such officer is necessary or 

appropriate to deal with the Physical Emergency, including, but not limited to, suspending 

trading in any one or more Contracts, delaying the opening of trading in any one or more 

Contracts, extending the Last Trading Day and/or the time of trading.

(2) In the event a designated officer has ordered suspension of trading, the Chairman of the 

Board or the Chief Executive Officer, or in their absence any other authorised officer may 

order restoration of trading on the Facility, or may remove other restrictions so imposed, if 

such officer determines that the Physical Emergency has sufficiently abated to permit the 

physical functions of IGDL or the Facility to continue in an orderly manner.

(f) IGDL will promptly report any action taken hereunder to the Commission and the FCA and 

explain the decision-making process, the reasons for the exercise of emergency authority and how any 

conflicts of interest were addressed. Any emergency Rule or Rule amendment shall be filed with the 

Commission in accordance with Part 40 of the Commission Regulations under the Act.
15

(g) In exercising its authority under this Rule 104, IGDL shall, in its reasonable discretion, and where 

appropriate, permitted by Applicable Law and not precluded by exigent circumstances, consult and 

coordinate with DCOs, other swap execution facilities, boards of trade, relevant Participants, and other 

parties in considering what actions to take hereunder.

Rule 105 Suspension of Trading

The Board may, in its discretion, by an affirmative vote of a majority of the Directors present at a meeting 

at which there is a quorum (which, in an Emergency other than a Physical Emergency, may be held 

without previous notice), close the Facility or suspend trading in any one or more Contracts on such days 

or portions of days as will, in its judgment, serve to promote the best interest of IGDL.

Rule 106 Risk Controls for Trading

The Regulatory Oversight Committee may impose controls to reduce the potential risk of market 

disruption, including but not limited to market restrictions that pause or halt trading in specified market 

conditions.

Rule 107 Market Data

(a) Subject to Rule 103, and each Participant’s and Customer’s rights in its own Proprietary Data and 

Personal Information, IGDL owns all rights, title and interest in and to all intellectual property and other 

proprietary rights (including all copyright, database rights, trademarks and trade secrets, or similar 

proprietary rights in any jurisdiction whether or not registrable) in and to any data, analytics, research or 

other information (including without limitation Bids/Offers, RFQs, Pre-Arranged Crosses, the contents of 

Confirmations and Trade Communications, such Confirmations and Trade Communications themselves, 

prices and volumes of transactions) contained in, displayed on, generated by or derived from the Facility 

and the Trading Platforms (collectively the “Information”). IGDL shall not decompile or reverse engineer 

any of a Participant’s or Customer’s Proprietary Data and Personal Information for the purpose of 

ascertaining such Participant’s or Customer’s trading strategies, except to the extent reasonably 

necessary for IGDL’s operations, to perform its surveillance and monitoring functions or to otherwise 

comply with Applicable Law. Subject to each Participant’s and Customer’s rights in its own Proprietary 

Data and Personal Information, each Participant and Customer (i) agrees to keep the Information 

confidential and cause each of its employees, Affiliates, Authorised Trading Firms, Customers, agents, 

consultants, independent software vendors and other persons affiliated with any of the foregoing, as 

applicable (collectively “Related Parties”), to keep the Information confidential, and (ii) agrees not to, and 

shall cause its applicable Related Parties not to, sell, lease, license, transfer, provide or otherwise make 

available to any third party any form of access to or use of any of the Information.

(b) Subject to paragraph (c) of this Rule 107, each Participant and Customer agrees that it shall not, 

and shall cause its Related Parties not to, license, sublicense, transfer, redistribute, resell, alter, enhance, 

make derivative works of, download to computer or reverse engineer all or any part of the Information 

(other than such Participant’s or Customer’s Proprietary Data and Personal Information).

(c) Notwithstanding paragraph (b) of this Rule 107:

(1) Solely (x) for use in connection with a Trading Privilege Holder’s own trading activity (and 

not, for the avoidance of doubt, for use by a Trading Privilege Holder’s sales, risk 

management (except for use by such Trading Privilege Holder’s compliance and other 

risk departments for regulatory purposes), research, wealth management or asset 

management departments/functions) or (y) to the extent necessary for a Trading Privilege 

Holder’s information technology department to perform transaction-related support 

functions for such Trading Privilege Holder, Trading Privilege Holders that:
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(i) pay the monthly TPH API Restricted Usage Minimum Fee, as described in 

IGDL’s Trade Execution Fee Card, as amended from time to time, shall be 

entitled to (x) download Information to a computer and/or (y) create Derived 

Information; and

(ii) pay the monthly TPH API Full Usage Minimum Fee, as described in IGDL’s 

Trade Execution Fee Card, shall be entitled to (x) download Information to a 

computer, (y) create Derived Information and/or (z) redistribute Derived 

Information (and only Derived Information).

(2) Customers that are Authorised Trading Firms for which a Trading Privilege Holder has 

provided DMA may have access to Information through such Trading Privilege Holder in 

connection with such Customer’s trading activity.

(d) IGDL shall bear no liability for any Derived Information, and each Trading Privilege Holder shall 

defend, indemnify and hold harmless each SEF Indemnified Party (as defined in Rule 108) from and 

against any Losses to which any SEF Indemnified Party may become subject, insofar as such Losses 

arise out of or in connection with, or are based upon any Proceeding against a SEF Indemnified Party 

that arises out of or relates to any Derived Information created by or on behalf of such Trading Privilege 

Holder or any of its Related Parties.

Rule 108 Intellectual Property

(a) The Systems are the exclusive Intellectual Property of IGDL or its affiliates or licensors. 

Participants have no access to the Systems and no rights with respect to the Systems, except as 

expressly granted by IGDL. Subject to any required approvals from any applicable Regulatory Agency, 

IGDL shall have the right to modify at any time a System’s functionality, configuration, appearance, 

content and the Swaps made available for trading via a System.

(b) Upon granting Trading Privileges to a Participant, IGDL grants to that Participant a revocable, 

non-exclusive, non-transferable license to access and use the Systems in accordance with the Rules for 

the sole purpose of (i) entering into Swaps via the Systems, and (ii) receiving and transmitting information 

generated by or made available through the Systems from time to time. Such license shall terminate 

when the Participant’s Trading Privileges terminate.

(c) Intellectual Property Rights

(1) By becoming a Participant, each Participant acknowledges and agrees that the 

Intellectual Property Rights in the Systems are a valuable asset of IGDL or its affiliates or 

licensors or their respective successors. Each Participant shall protect and safeguard the 

Intellectual Property Rights in and to the Systems by using the same degree of care that 

the Participant generally uses to protect its own Intellectual Property Rights and business 

assets, but in any event with no less than a reasonable degree of care.

(2) Each Participant shall promptly notify IGDL upon becoming aware of any infringement or 

misappropriation of any Intellectual Property Rights of IGDL or its affiliates or licensors. 

Each Participant shall comply with all reasonable requests made by IGDL (at IGDL’s 

reasonable expense) to protect and enforce the Intellectual Property Rights of IGDL or its 

affiliates or licensors in the Systems.

(d) Restrictions

(1) Subject to Rule 202, a Participant shall not sell, lease, license, transfer, provide or 

otherwise make available to any third party (including an affiliate of Participant), any form 

of access to or use of the System.
17

(2) A Participant shall not alter, enhance, make derivative works of, download to computer, 

decompile, disassemble or reverse engineer all or any part of the Systems except solely 

to the extent (i) expressly required by Applicable Law or permitted by the Rules, or 

(ii) necessary in direct connection with support functions related to transactions on or 

subject to the Rules.

(e) Notwithstanding Rule 102, IGDL represents and warrants that it owns or is licensed all Intellectual 

Property Rights in or to the Systems.

(f) Indemnities

(1) IGDL shall defend, indemnify and hold harmless each Participant and its officers, 

directors, employees and agents (each a “Participant Indemnified Party”) from and 

against all Losses as a result of any third party claim or proceeding of any nature 

(“Proceeding”) against a Participant Indemnified Party determining that the Systems 

(other than the EBS NDF System, which includes but is not limited to the technology 

known as EBS Dealing Service and Brokernet), or the use thereof by the Participant 

Indemnified Party as authorized hereunder, violates any Intellectual Property Rights of 

any third party provided that such Losses do not result from (i) any Participant 

Indemnified Party’s fraud, gross negligence or willful misconduct; (ii) violation of 

Applicable Law by the Participant Indemnified Party; or (iii) the Participant’s breach of the 

Rules.

(2) Each Participant shall defend, indemnify and hold harmless IGDL and each ICAP Party 

(each an “IGDL Indemnified Party”) from and against any Losses to which any IGDL 

Indemnified Party may become subject, insofar as such Losses arise out of or in 

connection with, or are based upon any Proceeding against an IGDL Indemnified Party 

that arises out of or relates to any access, use or misuse of the Systems by the 

Participant or by any person accessing the Systems using the Participant’s ID provided 

that such Losses do not result from (i) an IGDL Indemnified Party’s fraud, gross 

negligence or willful misconduct; (ii) violation of Applicable Law by the IGDL Indemnified 

Party; or (iii) the IGDL Indemnified Party’s breach of the Rules.

(3) If a Proceeding is commenced against a party entitled to indemnification under this 

Rule 108 (the “Indemnified Party”), notice shall be given to the party obligated to provide 

such indemnification (the “Indemnifying Party”) as soon as reasonably practicable. The 

Indemnifying Party shall be entitled to take control of the Proceeding and any settlement 

of it, and the Indemnified Party shall give the Indemnifying Party, at the Indemnifying 

Party’s reasonable cost, all reasonable assistance in relation to the Proceeding.

(4) Notwithstanding anything to the contrary contained in Rule 102 or a System Protocol, no 

limitation or exclusion of liability shall apply with respect to any direct losses or claims 

based on confidentiality, or to IGDL’s intellectual property infringement indemnification 

obligations set forth in this Rule 108.

(g) Confidentiality

Each Participant shall keep confidential all Confidential Information of IGDL or IGDL’s affiliates or 

licensors, both during the term and after termination of the license granted by this Rule 108. Each 

Participant may disclose Confidential Information to its professional advisers but otherwise may only 

disclose Confidential Information to those of its employees and representatives who need to know such 

Confidential Information for the purposes of exercising or performing the rights and obligations of 

Participant under the Rules and have been informed of the confidential nature of the Confidential 

Information divulged. No Participant will disclose Confidential Information to any third party except as 

follows: (i) with the consent of IGDL; (ii) as necessary to a DCO of which such Participant is a member or 

in connection with the clearing of a Swap; (iii) subject to appropriate confidentiality requirements no less 
18

stringent than the confidentiality provisions hereunder, to any person providing services to such party 

relating to transactions on or subject to the Rules; or (iv) to IGDL’s Regulatory Services Provider.

(h) Each Participant shall maintain commercially available virus checking software to protect itself 

and the Systems from viruses, notify IGDL immediately of any defect in the System or any unauthorized 

access or change to the System of which the Participant becomes aware and comply with any security 

measures and procedures for authentication required by IGDL from time to time.
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CHAPTER 2

TRADING PRIVILEGES

Rule 201 Trading Privilege Holders

(a) Trading Privileges

(1) Subject to the requirements and procedures set forth in this Chapter 2, Trading Privileges 

will be granted on an impartial basis to all applicants from time to time approved by IGDL 

as eligible to be Trading Privilege Holders, subject to any limitations or restrictions from 

time to time imposed by IGDL. Trading Privileges are non-transferable (except under 

certain limited circumstances which must be approved by IGDL), non-assignable and 

may not be sold or leased. Circumstances under which Trading Privileges may be 

transferred, subject to IGDL approval, include, for example, transfers due to corporate 

reorganisations. Each Trading Privilege Holder will have the right to access the Facility 

(including, subject to the applicable System Protocol, any Trading Platform) including the 

right to:

(i) place Bids/Offers, RFQs and Pre-Arranged Crosses for each of its proprietary 

accounts;

(ii) where permitted under this Rulebook and by Applicable Law, place Bids/Offers, 

RFQs and Pre-Arranged Crosses for the accounts of such Customers as an 

Intermediary; and

(iii) appoint other persons to act on its behalf as an Authorised Trader or Authorised 

Trading Firm pursuant to Rule 202, including providing DMA to a Customer.

(2) By virtue of obtaining Trading Privileges, a Trading Privilege Holder will not obtain any 

equity or other interest in IGDL or the Facility, including voting rights or rights to receive 

any dividends or other distributions, whether arising from a dissolution, merger or 

consolidation involving IGDL, the Facility or otherwise.

(3) In granting Trading Privileges, IGDL may impose such restrictions or limitations as it may 

deem necessary or appropriate, and in accordance with Applicable Law. IGDL shall 

apply such restrictions or limitations to applicants in an impartial, non-discriminatory 

manner, consistent with the Act, Commission Regulations and FCA rules thereunder. 

IGDL will deny the grant of Trading Privileges where an applicant has failed to meet any 

requirements for such grant.

(b) Financial Requirements

(1) Any person that wishes to have Trading Privileges must have sufficient resources to 

guarantee the adequate settlement of transactions pursuant to Rule 204, and must meet 

the other financial and related reporting requirements set forth in this Rule 201.

(2) Each Trading Privilege Holder must provide a signed written or electronic representation, 

prior to being granted access to the Facility, that it qualifies as an “eligible contract 

participant” as defined in the Act upon initial application for Trading Privileges.

(3) Each Trading Privilege Holder shall, no less frequently than annually, provide IGDL either 

with (i) its annual financial report that it provides to the Commission or (ii) a written or 

electronic representation providing that such Trading Privilege Holder has been, and 

continues to be as of such date, an “eligible contract participant” as defined in the Act.
20

(4) Each Trading Privilege Holder must notify IGDL’s Compliance Function immediately upon 

becoming aware that it fails to satisfy the minimum financial requirements applicable to it.

(5) Unless and until a Trading Privilege Holder is able to demonstrate to IGDL that it is in 

compliance with the minimum financial requirements applicable to it, such Trading 

Privilege Holder may not engage in any transactions subject to the Rules of the Facility, 

except for the purpose of closing open positions that were opened on the Facility.

(c) Fitness Standards

(1) IGDL may deny the grant of Trading Privileges, or may prevent a person from becoming 

an Authorised Trader or Authorised Trading Firm of a Trading Privilege Holder, if such 

person:

(i) is unable satisfactorily to demonstrate a capacity to adhere to all applicable 

Rules of the Facility or any Regulatory Agency, Rules of any DCO to which the 

Trading Privilege Holder submits Cleared Contracts for clearing, Commission 

Regulations and SRO regulations, including those concerning recordkeeping, 

reporting, financial requirements and trading procedures;

(ii) would bring IGDL or the Facility into disrepute; or

(iii) is otherwise not fit and proper to be a Trading Privilege Holder, Intermediary, 

Authorised Trader or Authorised Trading Firm.

(2) IGDL may determine not to permit a Trading Privilege Holder or any Authorised Trader or 

Authorised Trading Firm of a Trading Privilege Holder to keep its, his or her Trading 

Privileges or maintain his or her association with a Trading Privilege Holder, as the case 

may be, if such Trading Privilege Holder, Authorised Trader or Authorised Trading Firm:

(i) fails to meet any of the qualification requirements for Trading Privileges or 

Authorised Trader or Authorised Trading Firm status after such Trading 

Privileges or Authorised Trader or Authorised Trading Firm status has been 

approved;

(ii) fails to comply with any limitation placed by IGDL on such Trading Privileges or 

Authorised Trader or Authorised Trading Firm status; or

(iii) commits a material Violation.

(3) IGDL may deny the grant of Trading Privileges, or may prevent a person from becoming 

an Authorised Trader or Authorised Trading Firm, if they do not have a sufficient level of 

trading ability and competence or adequate organisational arrangements.

(4) Any decision made by IGDL pursuant to this Rule 201 must be consistent with both the 

provisions of this Rule and the Act and Commission Regulations and FCA rules 

thereunder.

(d) IGDL may (i) deny the grant of Trading Privileges, (ii) prevent a person from becoming an 

Intermediary or Authorised Trader or Authorised Trading Firm, and (iii) determine not to permit a Trading 

Privilege Holder or any Intermediary or Authorised Trader or Authorised Trading Firm to keep its, his or 

her Trading Privileges or maintain his, her or its association with a Trading Privilege Holder, as the case 

may be, if such Trading Privilege Holder, Intermediary, Authorised Trader or Authorised Trading Firm 

causes or would cause IGDL to be in violation of Applicable Law.
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(e) Consent to Facility Rules

Prior to obtaining access to the Facility and each time a Participant or Customer initiates or executes a 

transaction on the Facility, directly or through an Intermediary, each Participant and each Customer shall 

be deemed to have expressly consented to the jurisdiction of the Facility and agreed to be bound by and 

comply with the Rules. At the time any Clearing Firm provides a Clearing Firm Representation, each 

such Clearing Firm shall expressly consent to the jurisdiction of the Facility and agree to be bound by and 

comply with the Rules.

Rule 202 Authorised Traders and Authorised Trading Firms

(a) Each Trading Privilege Holder may from time to time permit one or more persons to enter 

Bids/Offers, issue and respond to RFQs, submit Pre-Arranged Crosses, access a Trading Platform and

effect transactions in Contracts on the Facility. Such authority may be granted to one or more Authorised 

Traders.

(1) Authorised Traders

(i) Each Trading Privilege Holder which is trading for its own account as a principal 

may permit one or more individuals as Authorised Traders to enter Bids/Offers 

and RFQs and Pre-Arranged Crosses on its behalf. In such case, the Trading 

Privilege Holder shall be principal to any resulting transactions made on its behalf 

by such Authorised Traders or to one or more Authorised Trading Firms.

(ii) Each Trading Privilege Holder which is an Intermediary trading for the accounts 

of Customers may permit one or more individuals as Authorised Traders to enter 

Bids/Offers and RFQs and Pre-Arranged Crosses on its behalf as an 

Intermediary for such Customers. In such cases, the Trading Privilege Holder 

has responsibility for all actions and failures to act of such Authorised Traders, 

but the Customer on whose behalf each transaction is made shall be the 

principal to any transactions made on its behalf by such Authorised Traders.

(iii) Each Trading Privilege Holder which is an Intermediary trading for the accounts 

of Customers that are natural persons may provide such a Customer with DMA 

to the Facility by permitting the Customer to become an Authorised Trader to 

enter Bids/Offers and RFQs on behalf of the Customer. In such case, the 

Customer shall be the principal to any transactions entered into as an Authorised 

Trader. As provided for in section (b)(3) below, IGDL may grant or deny DMA to 

a Customer in its sole discretion.

(iv) The Trading Privilege Holder shall be responsible to IGDL for acting with 

reasonable care in granting Authorised Trader status.

(2) Authorised Trading Firms

(i) Each Trading Privilege Holder which is an Intermediary trading for the accounts 

of Customers that are entities may provide such a Customer with DMA to the 

Facility by permitting the Customer to become an Authorised Trading Firm and 

by permitting one or more individuals associated with the Authorised Trading 

Firm to become Authorised Traders to enter Bids/Offers and RFQs on behalf of 

the Customer. In such case, the Customer on whose behalf each transaction is 

made shall be the principal to any transactions made on its behalf by such 

Authorised Trading Firm through the Authorised Traders. As provided for in 

section (b)(3) below, IGDL may grant or deny DMA to a Customer in its sole 

discretion.
22

(ii) [NOT USED]

(iii) The Trading Privilege Holder shall be responsible to IGDL for acting with 

reasonable care in granting Authorised Trading Firm status.

(iv) Each Trading Privilege Holder will obtain a signed written or electronic 

representation, prior to being granted access to the Facility, that each of its 

Authorised Trading Firms continues to qualify as an “eligible contract participant” 

as defined in the Act and provide such representation to IGDL and shall notify the 

SEF if any Authorized Trading Firm no longer qualifies as an “eligible contract 

participant”.

(b) IGDL Approval

(1) No person may act as an Authorised Trader or Authorised Trading Firm before being 

approved to do so by IGDL, which IGDL will do on an impartial basis.

(2) Each prospective Authorised Trader and Authorised Trading Firm, or the Trading 

Privilege Holder on their behalf, will, prior to being permitted by IGDL to act as an 

Authorised Trader or Authorised Trading Firm, as the case may be, submit an application 

in the form required by IGDL and will satisfy such requirements as may be prescribed by 

IGDL from time to time.

(3) Each prospective Authorised Trading Firm, or the Trading Privilege Holder on its behalf, 

must provide a written or electronic representation, prior to being granted access to the 

Facility, that the Authorised Trading Firm qualifies as (x) an “eligible contract participant” 

as defined in the Act, and (y) an Eligible Counterparty, and that it has all registrations, 

licenses and consents required by its constituent documents and Applicable Law to 

transact in Contracts. The foregoing representation may be provided directly to IGDL by 

the Authorised Trading Firm in a form provided by IGDL or, alternatively, the Trading 

Privilege Holder may provide IGDL evidence satisfactory to IGDL that the Authorised 

Trading Firm has provided such consents, agreements and representations to the 

Trading Privilege Holder.

(4) DMA to the Facility by an Authorised Trader or an Authorised Trading Firm shall be 

granted or denied in the sole discretion of IGDL. IGDL will notify a Trading Privilege 

Holder of its approval or disapproval of the designation of an Authorised Trader or 

Authorised Trading Firm for DMA. IGDL may, in its sole discretion, revoke or suspend 

the designation of an Authorised Trader or Authorised Trading Firm for DMA, and shall 

notify the Trading Privilege Holder of such action in accordance with procedures 

established by IGDL.

(c) Responsibilities to IGDL

(1) Each Trading Privilege Holder shall notify IGDL in writing if its relationship with an 

Authorised Trader or Authorised Trading Firm has been terminated, and such Trading 

Privilege Holder may at any time revoke any authorisation granted by it to any Authorised 

Trader or Authorised Trading Firm by providing written notice of such revocation to IGDL.

(2) By permitting any of its Authorised Traders and/or Authorised Trading Firm to access and 

use the Facility (including any Trading Platform) from any jurisdiction or to act as an 

Intermediary for trades on behalf of Customers located in any jurisdiction, each Trading 

Privilege Holder represents and warrants that each such access to or use of the Facility, 

or action as an Intermediary, does not violate any law applicable to the Trading Privilege 
23

Holder, the Authorised Trader, the Authorised Trading Firm or, to such Trading Privilege 

Holder’s knowledge, IGDL.

(d) Intermediation

(1) A Participant may not act as an Intermediary for any other entity or person, unless the

Trading Privilege Holder does so in accordance with Applicable Law.

(2) A Trading Privilege Holder may not transact as an Intermediary for any Customer unless 

the Trading Privilege Holder has submitted a signed representation to IGDL that each of 

its Customers is an “eligible contract participant” as defined in the Act and as an Eligible 

Counterparty.

Rule 203 Financial Integrity

(a) Each Trading Privilege Holder, Authorised Trading Firm and Customer must be an “eligible 

contract participant” as defined in the Act and an Eligible Counterparty (i) prior to obtaining access to the 

Facility, and (ii) at the time that such person enters into each transaction on the Facility or subject to the 

Rules.

(b) For Cleared Contracts:

(1) each Trading Privilege Holder or Authorised Trading Firm transacting on the Facility as a 

principal is required to demonstrate to IGDL, with appropriate documentary evidence as 

required by IGDL from time to time, that such Trading Privilege Holder or Authorised 

Trading Firm is a Clearing Firm or that it has clearing arrangements in place with a 

Clearing Firm, including having the Clearing Firm Representation required by Rule 204(f); 

and

(2) each Trading Privilege Holder acting as an Intermediary shall confirm that each of its 

Customers has clearing arrangements in place with a Clearing Firm and obtain from its 

Customers any documentary evidence as required by IGDL from time to time to that 

effect, including any Clearing Firm Representation required by Rule 204(f). The Trading 

Privilege Holder shall provide such documentary evidence to IGDL.

(c) For Contracts listed on the Facility as bilateral Contracts, each Trading Privilege Holder, 

Authorised Trading Firm or Customer that enters into such Contracts as a principal must undergo such 

credit checks and provide such credit information as the Facility may require from time to time.

Rule 204 Clearing

(a) All Contracts executed on the Facility that are subject to mandatory clearing under Section 2(h) of 

the Act must be cleared through a DCO by a Clearing Firm. Any other Contracts executed on the Facility 

may be cleared at the discretion of the parties to such transaction; provided that such Contracts are able 

to be cleared through a DCO by a Clearing Firm. After being submitted to and accepted by the relevant 

DCO, each Cleared Contract will be subject to the rules, policies and procedures of such DCO.

(b) Pre-Execution Credit Check / Risk Screening.

(1) In advance of submitting each Bid/Offer or Pre-Arranged Cross to the Facility for any 

Cleared Contract, each Trading Privilege Holder or Authorised Trading Firm shall identify 

the Clearing Firm to which any resulting transaction will be submitted for clearing at the 

relevant DCO and:
24

(i) if acting as principal, shall ensure that it has sufficient credit with such Clearing 

Firm for the resulting transaction and that the resulting transaction satisfies such 

Clearing Firm’s Risk-Based Limits; and

(ii) if acting as an Intermediary, other than with respect to DMA, shall confirm that its 

Customer has sufficient credit with the Customer’s Clearing Firm for the resulting 

transaction and that the resulting transaction satisfies such Clearing Firm’s RiskBased Limits.

In the event that there is insufficient credit or the transaction does not satisfy a Clearing Firm’s RiskBased Limits, the Trading Privilege Holder or Authorised Trading Firm may not submit such Bid/Offer or 

Pre-Arranged Cross to the Facility.

(2) Each Clearing Firm that provides a Clearing Firm Representation for a Participant or 

Customer may notify IGDL of the Risk-Based Limits it has established for such 

Participant or Customer, and such Risk-Based Limits shall become effective upon 

acknowledgment of receipt by IGDL. Any change to such Risk-Based Limits shall 

become effective only upon acknowledgment of receipt by IGDL.

(c) A Clearing Firm that seeks to effect transactions on the Facility for its own account or the account 

of any Customer must be a Trading Privilege Holder.

(d) IGDL may share information with any DCO that would assist such DCO in evaluating and 

monitoring a Clearing Firm’s compliance with these criteria. A Clearing Firm agrees to cooperate with 

IGDL and each relevant DCO in any such monitoring.

(e) Clearing Firms shall clear Cleared Contracts in accordance with all applicable Rules and DCO 

rules.

(f) Clearing Firm Representation

(1) Each Trading Privilege Holder or Authorised Trading Firm that is not a Clearing Firm and 

is transacting in Cleared Contracts on the Facility as a principal shall obtain a 

representation from a Clearing Firm, in form and substance satisfactory to, and approved 

by, IGDL (a “Clearing Firm Representation”). Under such representation, the Clearing 

Firm must accept for clearing all Cleared Contracts of each Trading Privilege Holder or 

Authorised Trading Firm for which it clears Cleared Contracts, subject to any Risk-Based 

Limits that are in effect pursuant to Rule 204(b)(2). Where a Trading Privilege Holder or 

Authorised Trading Firm uses the services of multiple Clearing Firms, a Clearing Firm 

shall be responsible only to the extent that it has been designated by such Trading 

Privilege Holder or Authorised Trading Firm to clear a particular Cleared Contract.

(2) Each Trading Privilege Holder acting as Intermediary shall obtain from the Customer a 

Clearing Firm Representation from a Clearing Firm pursuant to which the Clearing Firm 

accepts for clearing all transactions in Cleared Contracts entered into by the Customer, 

subject to any Risk-Based Limits that are in effect pursuant to Rule 204(b)(2). Where a 

Customer uses the services of multiple Clearing Firms, a Clearing Firm shall be 

responsible only to the extent that it has been designated by such Customer to clear a 

particular Cleared Contract.

(3) Every Contract that is subject to a Clearing Firm Representation and results from a 

Bid/Offer or Pre-Arranged Cross that is within any Risk-Based Limits that are in effect 

pursuant to Rule 204(b)(2) is deemed accepted for clearing by the Clearing Firm upon 

execution.
25

(4) A Clearing Firm may at any time (but on prior written notice to IGDL) revoke any Clearing 

Firm Representation made by it to a Trading Privilege Holder, Authorised Trading Firm or 

Customer (as applicable) in accordance with paragraph (1) and/or (2) above, by providing 

prior written notice of such revocation to IGDL. The Clearing Firm Representation will 

remain in effect for all Contracts for which Bids/Offers or Pre-Arranged Cross were 

submitted to a Trading Platform prior to IGDL’s acknowledgment of the revocation, which 

IGDL shall undertake to effectuate as promptly as practicable.

(5) Each Trading Privilege Holder, Authorised Trading Firm or, if applicable, Customer must 

assist its Clearing Firm and the DCO in the clearing of its Cleared Contracts.

(6) Upon notice that a Clearing Firm has revoked any authorisation granted and Clearing 

Firm Representation made by it to a Trading Privilege Holder, Authorised Trading Firm or 

Customer pursuant to this Rule 204(f), the right of such Trading Privilege Holder, 

Authorised Trading Firm or Customer (as applicable) to enter into Cleared Contracts will 

be automatically terminated, and such Trading Privilege Holder, Authorised Trading Firm 

or Customer must obtain another Clearing Firm Representation from a Clearing Firm 

before the Trading Privilege Holder’s, Authorised Trading Firm’s or Customer’s right to 

access to trade Cleared Contracts via the Facility will be reinstated.

(g) A DCO may be given access to the Facility for the purpose of obtaining any information required 

by the DCO to clear contracts, including, without limitation, real-time data regarding Bids/Offers, PreArranged Crosses and the execution of transactions. IGDL may impose such restrictions on a DCO’s 

access that it determines, in its sole discretion, are necessary and appropriate.

(h) Failure to Clear

(1) Subject to a Clearing Firm’s obligation to accept for clearing all Contracts resulting from 

Bids/Offers or Pre-Arranged Crosses that satisfy the Risk-Based Limits in effect for a 

Participant or Customer, any Cleared Contract, including one leg of a Package 

Transaction, that is rejected for clearing by a Clearing Firm or DCO for any reason, 

including an error by IGDL in permitting a Bid/Offer or Pre-Arranged Cross to be made 

that did not satisfy the Risk-Based Limits in effect at the time the Bid/Offer or PreArranged Cross was made, shall be void ab initio and will be cancelled by IGDL. For the 

avoidance of doubt, any component leg of a Package Transaction that was accepted for 

clearing will not be affected by the rejection of another leg of the same Package 

Transaction.

(2) Any Contract, including any component leg of a Package Transaction, that was executed 

on the Facility without the intent to be cleared, but later determined by the parties to the 

transaction to be cleared, will not be void if rejected for clearing by a DCO to which the 

Contract or component leg of the Package Transaction was submitted.

(3) In the event a Cleared Contract, including one leg of a Package Transaction, is cancelled 

by IGDL pursuant to this Rule 204(h), IGDL will report such cancellation to the relevant 

SDR pursuant to Part 43 of the Commission Regulations.

(4) Any transaction cancelled under this Rule 204(h) (except for transactions rejected by a 

DCO for credit reasons) may be re-executed pursuant to the procedures set forth in 

Rule 315(i).

(i) Submission of Cleared Contracts to DCOs

(1) IGDL shall route each Cleared Contract executed on the Facility and accepted for 

clearing by a Clearing Firm to the DCO identified pursuant to Rule 208(d) as soon as 
26

technologically practicable after execution, and in no event later than ten (10) minutes 

after execution. IGDL may do so either by submitting the Cleared Contract directly to the 

DCO or by routing the Cleared Contract through an Affirmation Hub.

(2) Cleared Contracts that are routed through an Affirmation Hub shall be routed in 

accordance with the following procedures:

(i) All Cleared Contracts executed as Pre-Arranged Crosses, via Voice RFQ or on 

the Order Book with the assistance of an Execution Specialist, must be Affirmed 

by Participants or Customers, as applicable, as soon as technologically 

practicable after execution, and in no event later than ten (10) minutes after 

execution; and

(ii) All other Cleared Contracts shall be automatically submitted by the Affirmation 

Hub to the relevant DCO as soon as technologically practicable after receipt from 

IGDL, without Participants or Customers being provided the opportunity to Affirm.

(3) Failure by a Participant or Customer to Affirm a Cleared Contract routed through an 

Affirmation Hub within the ten (10) minute time frame required by this Rule 204(i) shall be 

a Violation; provided that:

(i) such failure shall be a Violation only by the Participant(s) or Customer(s), as 

applicable, that failed to Affirm the Cleared Contract in accordance with this Rule; 

and

(ii) no such failure shall be a Violation where the failure was substantially the result 

of, as determined in IGDL’s discretion, any errors or delays caused by IGDL or 

any Execution Specialist.

(4) The Compliance Function or a designated member of the Market Regulation Staff shall, 

on a monthly basis, review the previous month’s Affirmations by Participants and 

Customers for compliance with this Rule 204(i). Notwithstanding such regular monthly 

reviews, the Compliance Function or any member of the Market Regulation Staff may 

investigate possible Violations of this Rule 204(i) at any time upon becoming aware of 

such possible Violation. Investigations of possible Violations of this Rule 204(i) shall be 

conducted in accordance with Rule 502, including that the Compliance Function may 

determine to impose summary fines in accordance with Rule 516. The Compliance 

Function or a designated member of the Market Regulation Staff shall review each 

possible Violation of this Rule 204(i) in light of all the facts and circumstances, including 

whether any errors or delays were caused by IGDL or any Execution Specialist.

(j) FICC Clearing Member Representation

(1) Each Trading Privilege Holder that is not a FICC Clearing Member and is transacting in 

the Swap component of a U.S. Dollar Swap Spread on the Facility as a principal shall 

provide evidence, in form and substance satisfactory to, and approved by, the Facility 

that a FICC Clearing Member will accept for clearing all U.S. Treasury Security 

components of a U.S. Dollar Swap Spread executed on the Facility prior to such time as 

the Facility acknowledges withdrawal of such obligation pursuant to Rule 204(j)(3) (a 

“FICC Clearing Member Representation”).

(2) Each Trading Privilege Holder acting as Intermediary shall obtain from the Customer 

evidence of a FICC Clearing Member Representation with respect to all U.S. Treasury 

Security components of a U.S. Dollar Swap Spread executed on the Facility for such 
27

Customer and submit such evidence to the Facility in form and substance satisfactory to, 

and approved by, the Facility.

(3) A Trading Privilege Holder, on its own behalf or on behalf of its Customer, as the case 

may be, may at any time withdraw any FICC Clearing Member Representation upon prior 

written notice of such withdrawal to the Facility and acknowledgement of such withdrawal 

by the Facility.

(4) Each Trading Privilege Holder or, if applicable, Customer must assist its FICC Clearing 

Member and FICC in the clearing of its Cleared Treasury Securities.

(5) Upon the withdrawal of a FICC Clearing Member Representation by a Trading Privilege 

Holder pursuant to Rule 204(j)(3), the right of such Trading Privilege Holder or its 

Customer (as applicable) to enter into the Swap component of U.S. Dollar Swap Spreads 

will be automatically terminated, and such Trading Privilege Holder (on its own behalf, or 

on behalf of its Customer, as the case may be) must provide new evidence of a FICC 

Clearing Member Representation from a FICC Clearing Member before the Trading 

Privilege Holder’s or Customer’s right to enter into the Swap component of U.S. Dollar 

Swap Spreads via the Facility will be reinstated.

(6) Each Participant or, where a transaction is on behalf of a Customer, the relevant 

Customer, is obligated to settle all U.S. Treasury Security components of a U.S. Dollar 

Swap Spread where the Swap component is traded on the Facility. Any failure to settle 

such U.S. Treasury component shall be a Violation; provided that, in the event FICC 

rejects such U.S. Treasury Security for clearing due to operational error beyond the 

control of the relevant Participant or Customer, the failure to settle such U.S. Treasury 

component shall not be a Violation.

(k) Breakage Agreements Prohibited. Participants and Customers are prohibited from requiring a 

Breakage Agreement from any other Participant or Customer as a condition of trading with that other 

Participant or Customer.

Rule 205 Application for and Grant of Trading Privileges

(a) Application Requirement. Each applicant for Trading Privileges will submit an application to IGDL 

in a form and manner prescribed by IGDL. Each applicant will promptly update the application materials if 

any of the information provided therein becomes inaccurate or incomplete after the date of submission 

and prior to any approval of the application. IGDL will act upon, and approve or disapprove, any such 

application without unreasonable delay.

(b) Upon submission of an application and satisfaction of the requirements and procedures set forth 

in this Chapter 2, and approval by IGDL, a person applying for Trading Privileges will be granted Trading 

Privileges. If the application process is not completed by the applicant within six months of submission of 

an application and payment of any applicable fee, the application will be deemed to be withdrawn.

(c) Any applicant who has been denied Trading Privileges or Authorised Trader or Authorised 

Trading Firm status with a Trading Privilege Holder, and any Trading Privilege Holder or Authorised 

Trader or Authorised Trading Firm of a Trading Privilege Holder who is not permitted to keep its, his or 

her Trading Privileges or maintain his or her status as an Authorised Trader or Authorised Trading Firm 

may request an appeal of IGDL’s decision pursuant to the procedures set forth in Rule 205(e). No 

determination of IGDL to discontinue a person’s Trading Privileges or Authorised Trader or Authorised 

Trading Firm status will take effect until the review procedures hereunder have been exhausted or the 

time for review has expired.
28

(d) Any applicant to become a Trading Privilege Holder who has been denied Trading Privileges 

pursuant to this Rule 205 will not be eligible for re-application during the six months immediately following 

such denial.

(e) Appeal of Denial of Trading Privileges or Suspension or Termination of Access

(1) If IGDL, pursuant to this Rule, denies an application for Trading Privileges or association 

with a Trading Privilege Holder as an Authorised Trader or Authorised Trading Firm, or 

determines not to permit a person to keep its Trading Privileges or maintain its 

association as an Authorised Trader or Authorised Trading Firm, or suspends or revokes 

a Participant’s or Customer’s access to the Facility pursuant to Rule 206(a) or (e), then, 

in any such case, the affected applicant, Trading Privilege Holder, Authorised Trader 

Authorised Trading Firm, Participant or Customer, as the case may be, within seven days 

after receiving written notice of such decision, may request in writing that IGDL provide 

the reasons therefor in writing. Within 14 days of receiving any such written request, 

IGDL will provide the applicant, Trading Privilege Holder, Authorised Trader, Authorised 

Trading Firm, Participant or Customer, as the case may be, with such reasons in writing. 

Within 14 days of receiving IGDL’s written response, the applicant, Trading Privilege 

Holder, Authorised Trader, Authorised Trading Firm, Participant or Customer, as the case 

may be, may request, in writing, that the Participation Committee reconsider IGDL’s initial 

decision and may provide any written representations or other information that the 

applicant, Trading Privilege Holder, Authorised Trader, Authorised Trading Firm, 

Participant or Customer, as the case may be, believes is relevant to the reconsideration.

(2) Within 28 days of receiving either a written request for reconsideration or written 

representations or information from the applicant, Trading Privilege Holder, Authorised 

Trader, Authorised Trading Firm, Participant or Customer, as the case may be, or a 

statement from such person that no such representation or information is to be made or 

supplied, the Participation Committee will either confirm, reverse or modify the initial 

decision and will promptly notify the applicant, Trading Privilege Holder, Authorised 

Trader, Authorised Trading Firm, Participant or Customer, as the case may be, 

accordingly. The Participation Committee may in its discretion schedule a hearing or 

establish any other process that it believes is necessary and appropriate to consider the 

request for reconsideration. Any decision by the Participation Committee pursuant to this 

subparagraph (2) constitutes the final action of IGDL with respect to the matter in 

question and is not subject to appeal. Any action that may be taken by the Participation 

Committee under this Rule 205(e) or (f) may be taken by the Board if no Participation 

Committee has been established.

(f) Effective Date of Denial of Trading Privileges or Suspension or Termination of Access

(1) If IGDL, pursuant to this Rule, makes a final determination to deny an application for 

Trading Privileges or association with a Trading Privilege Holder as an Authorized Trader 

or Authorized Trading Firm, or determines not to permit a person to keep its Trading 

Privileges or maintain its association as an Authorized Trader or Authorized Trading Firm, 

or suspends or revokes a Participant’s or Customer’s access to IGDL pursuant to 

Rule 206(a) or (e), then the Participation Committee shall provide written notice within 

thirty (30) days of its determination to the applicant, Participant or Customer, as 

applicable. The written notice must include:

(i) the name of the applicant, Participant or Customer;

(ii) a statement of the Participation Committee’s reasons for the denial of Trading 

Privileges, suspension or revocation of access to IGDL, including a listing of any 

Rules the Participation Committee determined were Violated and whether the 

Violation resulted in any financial harm to Customers;
29

(iii) a statement of the conclusions and findings of the Participation Committee with 

respect to each Violation, or, in the event of a settlement, a statement specifying 

the alleged Violations;

(iv) the terms of the denial of Trading Privileges, suspension or revocation of access 

to IGDL;

(v) the date on which the determination was made and the effective date of the 

determination; and

(vi) a statement informing the applicant, Participant or Customer that the denial of 

Trading Privileges, suspension or revocation of access to IGDL may be appealed 

to the Commission pursuant to Part 9 of the Commission Regulations.

(2) IGDL shall also provide the written notice to the NFA through the NFA’s Background 

Affiliation Status Information Center (“BASIC”), or deliver the written notice to NFA to be 

input into BASIC.

(3) Any decision by IGDL to deny Trading Privileges or to suspend or revoke access to IGDL 

pursuant to this Rule shall be the final decision of IGDL and shall become effective in 

accordance with the timeline set forth in Rule 513(b).

(4) If IGDL denies Trading Privileges or to suspends or revokes access to the SEF pursuant 

to this Rule, it must publicly publish the information contained in the written notice 

pursuant to Rule 205(f)(1).

Rule 206 Participant and Customer Obligations; Suspension or Termination of Access

(a) Each Participant and Customer must comply with these Rules, applicable provisions of the Act, 

and relevant Commission Regulations and FCA rules. Each Participant and Customer must also 

cooperate promptly and fully with IGDL, its agents, its Regulatory Services Provider, and/or a Regulatory 

Agency in any investigation, call for information, inquiry, audit, examination, or proceeding. Such 

cooperation shall include a duty to provide supplemental verbal or other information if the Participant or 

Customer learns that a previous response is incomplete or incorrect in any material respect. Additionally, 

each Trading Privilege Holder must update its email address promptly after any change and update all 

other material information provided in its application for Trading Privileges within five days after that 

information has changed. If any Participant or Customer fails to satisfy these obligations, IGDL may 

revoke or suspend the Participant’s or Customer’s access to the Facility in full or in part.

(b) Each Participant and Customer consents to allow IGDL to provide all information IGDL has about 

the Participant or Customer, including the Participant’s or Customer’s trading activity, to the Regulatory 

Services Provider, the Commission or any other Regulatory Agency, law enforcement authority, or judicial 

tribunal, including (as may be required by information sharing agreements or other contractual, 

regulatory, or legal provisions) foreign regulatory or self-regulatory bodies, law enforcement authorities, 

judicial tribunals and any other service provider to IGDL solely in connection with the service provider’s 

performance of services to IGDL and subject to the service provider’s agreeing to maintain such 

information as confidential, including that such service provider shall not:

(1) use such information for any purpose other than in connection with providing services to 

the Facility (including that it may not otherwise use such information for its own business 

or marketing purposes), unless specifically required in order to fulfill such service 

provider’s regulatory obligations; or

(2) disclose such information to any other person, except (i) to its employees or Affiliates, 

provided that the employees or Affiliates are subject to confidentiality obligations at least 
30

as stringent as those applicable to the service provider, and that, in each case, such 

disclosure is necessary for the performance of services to the Facility by the service 

provider, or (ii) if compelled to do so by valid legal or regulatory process, provided that 

the service provider notifies IGDL in advance thereof to the extent permitted.

(c) Each Participant is required to review the “Notices” section of IGDL’s website to make itself aware 

of material changes to these Rules or other notices that may affect their rights and obligations as a 

Participant.

(d) Each Trading Privilege Holder must diligently supervise all activities of the Trading Privilege 

Holder’s employees and/or agents, including all Authorised Traders and Authorised Trading Firms relating 

to transactions effected on the Facility. Any Violation by any employee of a Trading Privilege Holder, 

including an Authorised Trader or Authorised Trading Firm, shall constitute a Violation by such Trading 

Privilege Holder.

(e) IGDL may revoke or suspend a Participant’s access to the Facility in full or in part if the 

Participant acts as an Intermediary on behalf of a Customer and such Customer maintains a position in 

any Contract that, when considered in light of the other positions maintained by the Participant through 

which such Customer accesses the Facility, and any other factors that IGDL reasonably deems relevant, 

IGDL reasonably believes could jeopardise the financial safety of such Participant or any of such 

Participant’s other Customers. In making this determination, IGDL may consider any relevant factors, 

including, as applicable, (i) the positions maintained by such Participant, such Participant’s Authorised 

Traders, Authorised Trading Firms and other Customers, (ii) financial information provided by such 

Participant; and (iii) in consultation and coordination with the relevant DCOs, the level of margin 

maintained by such Participant at such Participant’s Clearing Firm.

(f) Each Trading Privilege Holder which is a Swap Dealer or Major Swap Participant and enters into 

or facilitates a Swap that is subject to mandatory clearing under Section 2(h) of the Act shall be 

responsible for compliance with the mandatory trading requirement under Section 2(h)(8) of the Act.

Rule 207 Customers

(a) No Participant shall act as an Intermediary unless the Trading Privilege Holder has entered into 

an agreement with the Customer that provides that the Customer agrees that all Contracts shall be 

governed by the Rules, the Act and the Commission Regulations and FCA rules, insofar as they are 

applicable to that Contract, although no such agreement shall be required by these Rules when the 

Customer of a Trading Privilege Holder is another Trading Privilege Holder.

(b) Where a Customer and Intermediary are both Trading Privilege Holders, the Customer shall 

provide IGDL with such notice of the relationship as IGDL may require from time to time.

(c) Each Customer shall be the principal to all executed transactions resulting from any Bids/Offers 

or Pre-Arranged Crosses entered on behalf of the Customer. Where a Participant is acting as an 

Intermediary on behalf of a Customer, the Participant shall have no liability, whether or not the identity of 

the Customer has been disclosed, in respect of any transactions executed on behalf of a Customer, to 

any other party, including any other Participant or the Customer of any other Participant.

(d) Except to the extent that IGDL sends Confirmations of Contracts directly to the relevant 

Customer, each such Customer authorises IGDL to send Confirmations of Contracts entered into through 

an Intermediary to the Intermediary and authorises such Intermediary to accept such Confirmations on 

behalf of the Customer.

Rule 208 Recordkeeping
31

(a) Each Participant and Customer must prepare and keep current all books, ledgers and other 

similar records required to be kept by it pursuant to Applicable Law and the Rules of the Facility.

(b) Each Participant and Customer shall keep records of the Swaps it trades on or subject to the 

Rules, and of its trading in each index, instrument or commodity underlying such Swaps, as well as of its 

trading of other derivatives that are based on any such index, instrument or commodity. These records 

shall include records of purchases, sales, ownership, production, processing and use of such Swaps, 

indices, instruments, commodities and derivatives, and may be in the form customarily generated in 

accordance with sound commercial practices in the relevant markets.

(c) Each Participant and Customer must keep all books and records required to be kept by it 

pursuant to the Rules for a period of five years from the date on which they are first prepared, unless 

otherwise provided in the Rules or required by Applicable Law. Such books and records must be readily 

accessible during the first two years of such five-year period. During such five- year period, all such 

books and records must, where Applicable Law requires it, be made available for inspection by, and 

copies thereof must be delivered to IGDL, IGDL’s Regulatory Services Provider, the Commission, the 

U.S. Department of Justice, the FCA, any other European Union regulatory agency governing a 

Participant and/or Customer and the authorised representatives of the foregoing, upon request.

(d) The following information must be provided to IGDL by each Participant prior to entering a 

Bid/Offer or Pre-Arranged Cross with respect to any Swap traded on the Facility:

• Authorised Trader ID

• Trading Privilege Holder ID

• Swap

• Series, if applicable

• DCO where Swap is to be cleared

• Price

• Quantity

• Side of the Bid/Offer

• Customer Type Indicator Code (defined below)

• Trading account and other relevant account information, including Clearing Firm

• LEI of the Participant placing the Bid/Offer or initiating the RFQ

• For Intermediated Transactions, the LEI of the Customer

• Yes/no indication of whether the Participant or Customer is a Swap Dealer for that Swap

• Yes/no indication of whether the Participant or Customer is a Major Swap Participant

• Yes/no indication of whether the Participant or Customer is a Financial Entity

• Yes/no indication of whether the Participant or Customer is a U.S. person as defined by 

the Commission;
32

• For Cleared Contracts, confirmation of the availability of credit at the Clearing Firm to 

which any resulting transaction will be submitted for clearing at the relevant DCO;

• Any information required by the applicable System Protocol; and

• If the Swap will be allocated:

o an indication that the Swap will be allocated;

o the LEI of the Account Manager;

o if the Swap is a pre-execution allocated Swap, the account and LEI for each 

Customer that will receive allocations;

o an indication of whether the Swap is a post-execution allocation Swap; and

o if the Swap is a post-execution allocation Swap, the unique Swap identifier of the 

original transaction between the reporting counterparty and the agent.

For purposes of this Rule 208, the “Customer Type Indicator Codes” are as follows:

CTI 1 – Bid/Offer for the proprietary account of a Trading Privilege Holder that is a natural person.

CTI 2 – Bid/Offer for the proprietary account of a Trading Privilege Holder that is not a natural 

person.

CTI 3 – Bid/Offer which an individual Trading Privilege Holder or Authorised Trader executes for 

the proprietary account of another Trading Privilege Holder or for an account which the other 

Trading Privilege Holder controls or has an ownership or financial interest in.

CTI 4 – Any Bid/Offer not meeting the definition of CTI 1, 2 or 3, including those entered on behalf 

of Customers.

(e) The Rules regarding the recordkeeping obligations set forth in this Rule 208 shall be promulgated 

to achieve the purposes and requirements of Applicable Law. While IGDL will have sole discretion, 

subject to Applicable Law, to determine such Rules, IGDL will take into consideration in doing so 

comparable requirements applicable to Participants.

Rule 209 Communications of IGDL with Participants

(a) Written Notices

IGDL will publish a notice with respect to each addition to, modification of, or clarification of the Rules, or 

of any action taken to implement any Rule, in a form and manner that is reasonably designed to enable 

each Trading Privilege Holder to become aware of and familiar with, and to implement any necessary 

preparatory measures to be taken by it with respect to, such addition or modification, prior to the effective 

date thereof; provided that any failure of IGDL to so publish a notice will not affect the effectiveness of the 

addition or modification in question. Each Trading Privilege Holder will provide its respective Authorised 

Traders, Authorised Trading Firms and Customers with copies of any such notice. For purposes of 

publication in accordance with the first sentence of this Rule 209(a), it will be sufficient (without limiting 

the discretion of IGDL as to any other reasonable means of communication) if a notice is (a) sent to each 

Trading Privilege Holder by mail, recognised courier service, facsimile or electronic mail (including by 

means of a hyperlink included in an electronic mail message), to the address, facsimile number or 

electronic mail address (as applicable) provided by such Trading Privilege Holder for such purpose or 

(b) published on the Facility’s website. Each Trading Privilege Holder, on its own behalf, and on behalf of 
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its Authorised Traders, Authorised Trading Firms and Customers, as applicable, must monitor the 

Facility’s website for any notices published under this Rule 209(a).

(b) Recording of Communications

IGDL and Trading Privilege Holders may record conversations and retain copies of electronic 

communications between officers, employees or agents of IGDL, on the one hand, and Trading Privilege 

Holders (including their Affiliates), Authorised Traders, Authorised Trading Firms or Customers, on the 

other hand. Any such recordings or other records may be retained by IGDL or such Trading Privilege 

Holder, as the case may be, in such manner and for such periods of time as IGDL, or such Trading 

Privilege Holder, as the case may be, may deem necessary or appropriate.

Rule 210 Required Disclosures to IGDL

Each Trading Privilege Holder must promptly notify IGDL in writing upon becoming aware:

(a) that the Trading Privilege Holder, any of the Trading Privilege Holder’s officers or any of the 

Trading Privilege Holder’s Authorised Traders or Authorised Trading Firms has been the subject of a 

material sanction, penalty or other adverse action by any Regulatory Agency which is related to 

transactions in Swaps, futures, options on futures, securities, commodities, or Swaps-related banking;

(b) that the Trading Privilege Holder, any of the Trading Privilege Holder’s officers or any of the 

Trading Privilege Holder’s Authorised Traders or Authorised Trading Firms has been convicted of, pled 

guilty or no contest to, or entered in a plea agreement of a material nature in any domestic, foreign or 

military court which involves:

(1) embezzlement, theft, extortion, fraud, fraudulent conversion, forgery, counterfeiting, false 

pretences, bribery, gambling, racketeering, or misappropriation of funds, securities or 

properties; or

(2) any transaction in or advice concerning Swaps, futures, options on futures, securities, 

commodities, or Swaps-related banking;

(c) that the Trading Privilege Holder, any of the Trading Privilege Holder’s officers or any of the 

Trading Privilege Holder’s Authorised Traders or Authorised Trading Firms is subject to material 

regulatory proceedings before any Regulatory Agency which are related to transactions in Swaps, 

futures, options on futures, securities, commodities, or Swaps-related banking;

(d) that the Trading Privilege Holder, any of the Trading Privilege Holder’s officers or any of the 

Trading Privilege Holder’s Authorised Traders or Authorised Trading Firms have been denied or 

withdrawn any application for registration or license submitted to any Regulatory Agency, and of any 

material revocation, suspension or conditioning of any registration or license granted by any Regulatory 

Agency, which in each case is related to transactions in Swaps, futures, options on futures, securities, 

commodities, or Swaps-related banking;

(e) that any of the Trading Privilege Holder’s Authorised Traders or Authorised Trading Firms have:

(1) had their status as an Authorised Trader or Authorised Trading Firm permanently 

revoked by the Trading Privilege Holder, whether due to employment termination, 

termination of status as a Customer or otherwise; or

(2) had their access to the Facility temporarily revoked by the Trading Privilege Holder;
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(f) of any material change:

(1) in any information contained in the Trading Privilege Holder’s membership application, or 

in an Authorised Trader’s or Authorised Trading Firm’s application pursuant to Rule 202, 

including a Trading Privilege Holder’s, Authorised Trading Firm’s or Customer’s status as 

an “eligible contract participant” or an Eligible Counterparty; or

(2) to an Authorized Trader’s or Authorized Trading Firm’s signed representation to IGDL 

that each of its Customers is an “eligible contract participant” pursuant to Rule 202(d);

(g) of any withdrawal from membership by the Trading Privilege Holder, any of the Trading Privilege 

Holder’s officers or any of the Trading Privilege Holder’s Authorised Traders or Authorised Trading Firms, 

in any SRO, designated contract market, DCO or swap execution facility;

(h) of any damage to, or failure or inadequacy of, the systems, facilities or equipment used to effect 

transactions or perform financial obligations under or in connection with Contracts of the Trading Privilege 

Holder or any of its Authorised Traders or Authorised Trading Firms;

(i) of any change in the location of the principal office of the Trading Privilege Holder or any of the 

Trading Privilege Holder’s Authorised Traders or Authorised Trading Firms;

(j) of any failure to maintain segregated funds as required by the Commission when the Trading 

Privilege Holder is a futures commission merchant registered with the Commission;

(k) of becoming subject to early warning reporting under Commission Regulation 1.12; and

(l) of becoming the subject of a bankruptcy proceeding or being unable to meet any financial 

obligation as it becomes due.

Rule 211 Dues, Fees and Expenses

(a) The Board has the sole power to set the payment dates and amounts of any dues, assessments 

or fees to be levied on Trading Privilege Holders, which dues, assessments or fees will be paid to IGDL 

the when due. Fees will be comparable for Trading Privilege Holders receiving comparable access to, or 

services from, IGDL.

(b) If a Trading Privilege Holder fails to pay when due any IGDL dues, assessments or fees levied on 

such Trading Privilege Holder, and such payment obligation remains unsatisfied thirty (30) days after its 

due date, IGDL may suspend, revoke, limit, condition, restrict or qualify the Trading Privileges of such 

Trading Privilege Holder as it deems necessary or appropriate.

Rule 212 Market Maker Programs

IGDL may from time to time adopt, pursuant to Part 40 of the Commission Regulations, one or more 

programs under which one or more Trading Privilege Holders or others may be approved and designated 

as market makers with respect to one or more Contracts in order to provide liquidity and orderliness in the 

market or markets for such Contract or Contracts. Any such program may provide for any or all of the 

following:

(a) qualifications, including any minimum net capital requirements, that any such market maker must 

satisfy;

(b) the procedure by which Trading Privilege Holders or others may seek and receive designation as 

market holders;
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(c) the obligations of such market makers, including any applicable minimum bid and offer 

commitments;

(d) the benefits accruing to such market makers, including priority in the execution of transactions 

effected by Trading Privilege Holders or others as approved by IGDL in their capacity as market makers, 

reduced transaction fees or the receipt of compensatory payments from IGDL;

(e) the requirement that such designated market makers agree to abide by the Rules and are subject 

to the jurisdiction of the Facility; and

(f) any pre-trade trade transparency requirements that may apply to the best Bid/Offer prices and 

volumes of any such market makers.

Rule 213 Independent Software Vendors

IGDL shall provide impartial access to independent software vendors who enter into a development and 

maintenance agreement with IGDL (an “ISV Development and Maintenance Agreement”). Fees will be 

comparable for independent software vendors receiving comparable access to, or services from, IGDL. 

Each independent software vendor that enters into an ISV Development and Maintenance Agreement 

must satisfy the following criteria, which IGDL shall apply in a fair and nondiscriminatory manner:

(a) If required to be registered in any capacity under Applicable Law, it has duly registered in such 

capacity and such registration is in effect and has not lapsed or been revoked, suspended or withdrawn;

(b) It complies with the applicable technical access standards, system compatibility requirements, 

security protocols and technical specifications for connection to IGDL’s electronic systems as may be 

specified by IGDL from time to time;

(c) It must ensure that each person that uses the independent software vendors to access the 

Facility is either a Participant or a Customer of a Participant authorised as such in accordance with these 

Rules;

(d) It may provide data obtained from the Facility solely to such Participants or Customers of 

Participants in connection with their actual and proposed trading activity in Contracts and similar 

contracts, and shall not provide such data to any other swap execution facility, security-based swap 

execution facility, designated contract market, national securities exchange or other trading facility or 

system without the prior written consent of IGDL;

(e) In the case of any RFQ or Bid/Offer submitted to IGDL through an independent software vendor, 

the independent software vendor will provide sufficient detail to identify the Participant (and, in the case of 

a Customer transaction, the Customer) as required by IGDL; and

(f) It satisfies such other impartial and transparent criteria as IGDL may specify from time to time, 

subject to Applicable Law.

Rule 214 Withdrawal of Participant

(a) To withdraw from the Facility, a Participant must notify IGDL in writing, following such procedures 

as may be established by IGDL.

(b) IGDL may, in its reasonable discretion, refuse to accept a Participant’s withdrawal request or may 

postpone the effective date of withdrawal of a Participant if IGDL considers it necessary for the protection 

of the Participant’s Customers, other Participants or otherwise in the interests of IGDL.
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(c) Based on the information provided to, and other information gathered by, IGDL regarding a 

Participant’s withdrawal request, IGDL will determine whether to: (i) accept the withdrawal request; 

(ii) postpone the effective date of the withdrawal; or (iii) impose any terms or conditions before or after the 

effective date of withdrawal.

(d) If IGDL refuses to accept a Participant’s withdrawal request or postpones the effective date of 

withdrawal of a Participant, IGDL may waive the obligation to pay some or all of the fees, costs and 

charges that IGDL would have imposed during the period after the date on which the requested 

withdrawal would have otherwise taken effect.

(e) When IGDL accepts the withdrawal of a Participant, all rights and privileges of such Participant 

terminate (including the Trading Privileges and ability to access a Trading Platform). The accepted 

withdrawal of a Participant shall not affect the rights of IGDL under the Rules or relieve the former 

Participant of its obligations with respect to previously executed transactions (including any contractual 

obligations relating to any Contracts entered into by such Participant, or the payment of any fees, costs, 

or charges incurred prior to such withdrawal). Notwithstanding the accepted withdrawal of a Participant, 

the withdrawn Participant remains subject to the jurisdiction of the Facility for acts done and omissions 

made while a Participant, and must cooperate in any proceeding under Chapter 5 as if such withdrawal 

had not taken place.

(f) Upon delivery of a withdrawal notice:

(1) Participant shall promptly notify its Authorised Traders and Authorised Trading Firms that 

they may no longer access the Facility on behalf of Participant, and Participant shall with 

reasonable diligence, to the extent practicable, terminate electronic access of its 

Authorised Traders and Authorised Trading Firms to the Facility; and

(2) IGDL shall suspend Participant’s access to the Facility, promptly notify its relevant 

personnel that Participant and its Authorised Trading Firms may no longer access the 

Facility on behalf of Participant, and with reasonable diligence, to the extent practicable, 

terminate electronic access of Participant’s Authorised Traders to the Facility.
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CHAPTER 3

TRADING PROCEDURES

Rule 301 Trading Sessions

Except as otherwise provided in these Rules or determined by the Board, transactions in any Contract will 

only be executed during the Trading Session for such Contract. IGDL may from time to time modify its 

regular Trading Session and establish Trading Sessions, in addition to the regular Trading Sessions, as it 

deems appropriate.

Rule 302 Information about, and access to, IGDL’s Order Book

(a) Each Authorised Trader and each Trading Privilege Holder that is an individual will receive a user

identification (“ID”) and password. As a Trading Privilege Holder or Authorised Trader, such person will 

be able to access IGDL’s Order Book, which functions as an electronic central limit order book and 

provides the highest priority to Bids/Offers with the best price, for trading in the Swap asset classes or 

sub-products approved for such Trading Privilege Holder or Authorised Trader, enter and accept 

Bids/Offers, and otherwise access information regarding, or perform functions for, such person’s account

using its ID and password.

(b) For account security and audit trail purposes, each Trading Privilege Holder and Authorised 

Trader agrees that IGDL may maintain logs of the IP address used to log on to any Order Book.

(c) Each Trading Privilege Holder will be responsible for protecting from improper disclosure its ID 

and password, and the IDs and passwords of its Authorised Traders. In addition, a Trading Privilege 

Holder may not knowingly or negligently permit any person not authorised by IGDL and by the Trading 

Privilege Holder to use the ID and password to access the Order Book. Each Trading Privilege Holder is 

required to immediately notify IGDL if it knows, or has reason to believe, that its ID and/or password, or 

the ID and/or password of any Authorised Trader have been disclosed to any person not authorised by 

IGDL and the Trading Privilege Holder to use such ID and/or password.

(d) Except as otherwise provided in Rule 102.

(1) each Trading Privilege Holder will be liable for all costs and any losses that it may incur 

from transactions executed on the Facility by any person, authorised or not, using its ID 

and password or the ID and/or password of any of its Authorised Traders; and

(2) IGDL will not be responsible in any way for unauthorised transactions for a Trading 

Privilege Holder’s account.

(e) Each Trading Privilege Holder is responsible for contracting with a network provider through 

which it will access the Facility and for having a backup service provider if the Trading Privilege Holder 

deems it necessary. Each Trading Privilege Holder is also responsible for maintaining a network 

connection speed adequate for its needs. IGDL will not be responsible in any way for any Bids/Offers 

delayed or transactions missed or not executed in a timely fashion because of failure of the Trading 

Privilege Holder’s Internet service provider or slowness of its network connection speed. No 

communication from a Trading Privilege Holder will be deemed to have been received by IGDL until that 

communication is logged by the Order Book server.

Rule 303 Required Transactions

(a) No Participant shall execute a Required Transaction on the Facility other than via the Facility’s 

Order Book or Request for Quote procedures, unless such transaction is a Block Trade, in which case it 

shall be executed in accordance with Rule 308.
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(b) Upon execution of a Required Transaction on the Facility, IGDL will report the transaction to the 

SDR as soon as technologically practicable after execution in accordance with Rule 309.

(c) Package Transactions. In accordance with NAL 16-76, expiring November 15, 2017, a 

Participant may execute a Swap component of a Covered Package Transaction through any method of 

execution offered by the Facility, notwithstanding that execution of such Swap component would 

otherwise be a Required Transaction.

Rule 304 Permitted Transactions

(a) Participants may enter Bids/Offers for Permitted Transactions directly into the Facility’s Order 

Book for that Contract.

(b) Participants may submit to an Execution Specialist for execution Permitted Transactions

negotiated and agreed to outside the Facility’s Order Book, at prices mutually agreed, with regard to 

Contracts that have been designated by IGDL for such purpose (each such transaction a “Pre-Arranged 

Cross”). Pre-Arranged Crosses that are submitted to an Execution Specialist for execution must be 

submitted by the seller, unless otherwise agreed to by the parties; however, in the case of an 

Intermediated Transaction, the Participant acting as the Intermediary shall have the obligation to submit 

the Pre-Arranged Cross to the Execution Specialist. The Participant submitting the Pre-Arranged Cross 

to the Execution Specialist must provide the information required by Rule 208(d).

(c) An Execution Specialist may facilitate the negotiation and execution of a Pre-Arranged Cross by 

two Participants only as follows: upon request of a Participant, the Execution Specialist may, without 

using any Trading Platform, Order Book or RFQ procedure, contact one or more other Participants to 

determine interest in a Pre-Arranged Cross.

(d) Upon execution of the Permitted Transaction on the Facility, IGDL will report the transaction to 

the SDR as soon as technologically practicable after execution in accordance with Rule 309.

(e) Each Participant that is party to, or Intermediary in, a Pre-Arranged Cross executed pursuant to 

section (b) of this Rule 304 must record the following details of the transaction: the Contract (including 

the Delivery Month) to which such transaction relates; the number of Contracts traded; the price of 

execution or premium; the identity of the counterparty; and, if applicable, details regarding the Customer 

for which the transaction was executed, as well as, if applicable, the Underlying Interest and whether the 

transaction involved a put or a call and the strike price. Upon request by IGDL, such Participant must 

produce satisfactory evidence, including the transaction information referred to in the preceding sentence 

that the transaction meets the requirements set forth in this Rule.

Rule 305 Execution Methods for Required Transactions

(a) Execution through the Order Book

(1) A Participant may enter Bids/Offers to transact in Contracts by electronic transmission 

over a network or through an Execution Specialist. If a Participant submits a Bid/Offer to 

the Order Book through an Execution Specialist, the Execution Specialist shall provide 

the Participant with a confirmation that the Bid/Offer was entered into the Order Book as 

soon as possible after such entry. Neither the Order Book nor an Execution Specialist 

will disclose the identities of Participants submitting Bids/Offers prior to the execution of a 

transaction through the Order Book.

(2) A Participant will enter a Bid/Offer to transact in one or more Contracts by indicating to 

the Facility in the manner required by a Trading Platform or the Execution Specialist the 

information required by Rule 208(d).
39

(3) The Participant will be responsible for any and all Bid/Offer entries it posts on the Facility. 

Posted Bids/Offers are subject to acceptance by other Participants.

(4) The Order Book will keep an electronic record of all Bids/Offers to transact in Contracts, 

and all executed transactions.

(5) The records kept by IGDL will include all of the Bid/Offer terms identified in this Rule as 

well as the date and time that the transaction was executed.

(6) The Order Book will provide Participants with the ability to post firm Bids/Offers on a 

centralised electronic screen that is accessible to all Participants with access to the Order 

Book. Each Participant may then choose to transact on the basis of a firm Bid/Offer by 

entering a Bid/Offer which accepts the firm Bid/Offer.

(7) For a Participant who has the ability to accept a Bid/Offer it submits on behalf of a 

Customer or to execute Bids/Offers from two Customers against each other, or for two 

Participants who desire to execute offsetting Bids/Offers as a result of pre-execution 

discussions, the Participant or Participants must allow at least a 15 second delay 

between the entry of those two Bids/Offers, such that one side of the potential transaction 

is disclosed and made available to other Participants for at least 15 seconds (or such 

other time as IGDL may publish for particular contracts) before the second side of the 

potential transaction, whether for the Participant’s own account or for Participant’s 

Customer, is submitted for execution. Participants and Customers may engage in 

pre-execution discussions with regard to such Bids/Offers in accordance with 

Rule 404(c).

(b) [NOT USED]

(c) Voice Request for Quote Systems. Participants may initiate either a Non-Directed Voice RFQ or 

a Directed Voice RFQ by contacting an Execution Specialist. If the Participant does not specify that it 

wishes the RFQ to go to less than all Participants, the Execution Specialist shall direct the RFQ to all 

Participants.

(1) Non-Directed Voice RFQ.

(i) The Execution Specialist will transmit the RFQ to all other Participants, and all 

other Participants may respond.

(ii) Prior to execution the Execution Specialist will not disclose the identities of 

Participants who transmit or respond to a Non-Directed Voice RFQ.

(2) Directed Voice RFQ.

(i) The Execution Specialist will transmit the RFQ to no less than three 

(3) Recipients, to which all such Recipients may respond.

(ii) A Participant that requests an Execution Specialist to send an RFQ to fewer than 

all Participants may not request that an Execution Specialist send any RFQ to 

another Participant that is affiliated with or controlled by the RFQ requester or to 

two more Participants that are affiliated with or controlled by each other. An 

Execution Specialist that sends an RFQ to fewer than all Participants, after 

consideration of reasonably available information, may not knowingly send an 

RFQ on behalf of the requesting Participant to another Participant that is affiliated 

with or controlled by the RFQ requester, or to two or more Participants that are 

affiliated with or controlled by each other. For purposes of this Rule 305(c), 
40

“control” includes but is not limited to the grant of trading discretion by one 

Participant to another.

(iii) The identity of a Directed Voice RFQ requester shall be disclosed to the 

Recipients upon transmittal of any Directed Voice RFQ and the identities of the 

Recipients that provide responses shall be disclosed to the RFQ requestor at the 

time of such responses.

(iv) A Participant may elect to not receive Directed Voice RFQs upon written notice to 

the Facility.

(3) With respect to both Non-Directed Voice RFQs and Directed Voice RFQs:

(i) Together with the first response from any Recipient, the Execution Specialist will 

communicate to the requesting Participant any firm resting Bid/Offer for the Swap 

indicated in the RFQ that is posted in the Order Book together with any 

responses to the RFQ from the Recipients.

(ii) Responses to RFQs must be in the form of a Bid/Offer. The RFQ requestor may 

accept such RFQ response by submitting a corresponding Bid/Offer.

(iii) An Execution Specialist will act in accordance with a Participant’s instructions, 

the Rules and Applicable Law.

(4) Managed Orders. With respect to Non-Directed Voice RFQs only:

(i) Unless otherwise instructed by a Recipient, an unfilled Bid/Offer provided in 

response to an RFQ shall be entered into the Order Book by an Execution 

Specialist on behalf of a Participant (“Managed Orders”).

(ii) Execution Specialists shall cancel a Managed Order if:

A. The Participant instructs the Execution Specialist to cancel the Managed 

Order;

B. The Participant is filled in the same instrument in an RFQ and the 

Managed Order is filled prior to the Execution Specialist cancelling the 

order; or

C. Time has passed and market conditions have changed sufficiently since 

the entry of the Managed Order such that the Managed Order should be 

cancelled. The following conditions must be met before a Managed 

Order is cancelled in the Order Book:

(aa) The Managed Order must be exposed to the Order Book for at 

least 15 seconds; and

(bb) A material change in the equilibrium price of the particular 

instrument has occurred as identified by any of the following:

i. New Bids/Offers, initiations of Voice RFQs, or responses 

to Voice RFQs indicating one or more Participants are 

willing to trade at a worse price; or
41

ii. The instrument’s mid-rate has moved through the 

Managed Order’s price; or

iii. A material economic market event has occurred, 

including, but not limited to, U.S. Department of Labor’s 

Bureau of Labor Statistics Economic News Releases, 

Federal Reserve announcements, or natural or manmade disasters.

(iii) Failure of an Execution Specialist to cancel a Managed Order pursuant to 

305(c)(3)(b)(ii) prior to it being filled in whole or in part shall be considered an 

error of the Facility that may be cancelled pursuant to Rule 315(a).

Rule 306 Work Up

Work-up sessions in Required Transactions are permitted in both electronic trading and RFQ, subject to 

the System Protocol for the Trading Platform for each product. Work-up transactions do not qualify as a 

Block Trade even if a Participant’s transactions as part of the work-up session has a notional or principal 

amount at or above the appropriate minimum block size applicable to such Swap.

Rule 307 Acceptable Bids and Offers

(a) The Bid/Offer types shall be as specified in the appropriate System Protocol.

(b) A Participant submitting a Held Order for less than the Appropriate Minimum Block Size for 

execution on the Facility shall submit such a Held Order directly to the Order Book or, if submitted to the 

Facility through an Execution Specialist, such Execution Specialist shall submit such a Held Order directly 

to the Order Book.

Rule 308 Block Trades

Participants must enter into uncleared Block Trades away from the Facility, i.e., outside a Trading 

Platform, System, Order Book, RFQ procedure or Prearranged Cross procedure under Rule 304(b). 

Participants may enter into Block Trades in Cleared Contracts in accordance with Rule 308(f). All Block 

Trades must be executed at prices mutually agreed, with regard to Contracts that have been designated 

by IGDL for such purpose, subject to the following conditions:

(a) The Block Trade must be for at least such minimum number of Contracts as will from time to time 

be specified by IGDL (the “Appropriate Minimum Block Size”). Except as may otherwise be permitted 

by Commission Regulation 43.6(h)(6), Participants shall not aggregate Contracts of different Participants 

or Customers to achieve the Appropriate Minimum Block Size. Furthermore, each leg of a Package 

Transaction must achieve the Appropriate Minimum Block Size independently of each other leg of the 

Package Transaction. The current Appropriate Minimum Block Sizes are posted on the “Regulation” 

section of the IGDL website.

(b) When negotiating or executing a Block Trade, a Participant must ensure that the price quoted for 

a Block Trade represents a fair and reasonable price. The price at which a Block Trade is executed must 

be fair and reasonable in light of (i) the size of such Block Trade, (ii) the prices and sizes of other 

transactions in the same Contract at the relevant time, (iii) the prices and sizes of transactions in other 

relevant markets at the relevant time, and (iv) the circumstances of the parties to such Block Trade.

(c) Block Trades that are not Cleared Contracts must be reported to the Facility by the seller, unless 

otherwise agreed to by the parties, as soon as technologically practicable after execution, and in no event 

later than ten (10) minutes after execution, by contacting an Execution Specialist; however, in the case of 

an Intermediated Transaction, the Participant acting as the Intermediary shall have the obligation to report 
42

the Block Trade to the Facility as soon as technologically practicable after execution. The Participant 

reporting the Block Trade to the Facility must explicitly state to the Execution Specialist that the parties 

are electing to have the Block Trade treated as such, must state the time of execution to the nearest 

second and must provide the information required by Rule 208(d).

(d) IGDL will review the information submitted by the Participants for a Block Trade that is not a 

Cleared Contract and will post the transaction to a Trading Platform if the details are complete and 

accurate in accordance with this Rule. IGDL will report the transaction to the SDR as soon as 

technologically practicable after execution in accordance with Rule 309 and will identify the Block Trade 

as such in the report. IGDL will not disclose any detail of a Block Trade that is not a Cleared Contract 

prior to the public dissemination of the Block Trade by the SDR.

(e) Each Participant that is party to, or Intermediary for, a Block Trade that is not a Cleared Contract 

must record the following details of the transaction: the Contract (including the Delivery Month) to which 

such transaction relates; the number of Contracts traded; the price of execution or premium; the time of 

execution; the identity of the counterparty; and, if applicable, details regarding the Customer for which the 

transaction was executed, as well as, if applicable, the Underlying Interest and whether the transaction 

involved a put or a call and the strike price. Upon request by IGDL, such Participant must produce 

satisfactory evidence, including the information referred to in the preceding sentence that the transaction 

meets the requirements set forth in this Rule.

(f) In accordance with NAL 16-74, expiring November 15, 2017, a Participant may execute a Block 

Trade that is a Cleared Contract either (i) via the Facility’s voice RFQ procedures in Rule 305(c), with the 

exception that there shall be no minimum number of required Participants to whom an RFQ must be sent, 

or (ii) as a Pre-Arranged Cross in accordance with the procedures in Rule 304, notwithstanding that the 

execution of the Block Trade does not occur away from the Facility’s trading system. Each Block Trade 

executed pursuant to this Rule 308(f) must involve Contracts listed by the Facility, be executed pursuant 

to the Rules and meet the Appropriate Minimum Block Size. The Facility will report each Block Trade 

transaction to the SDR as soon as technologically practicable after execution in accordance with 

Rule 309. The Facility will not disclose any detail of such a Block Trade prior to the public dissemination 

of the Block Trade by the SDR.

(g) Each counterparty to a Block Trade must be an “eligible contract participant” as defined in the 

Act.

(h) Each Intermediary entering into a Block Trade on behalf of a Customer (or in the case of an 

Authorised Trader acting as an Intermediary, its Trading Privilege Holder’s Customer) must have received 

a written instruction or consent to do so from the Customer prior to the execution of the Block Trade. The 

written instruction or consent must be specific as to Block Trades but may be included in a power of 

attorney or similar document in which the Customer provides the Intermediary with discretionary trading 

authority to direct the trading in the Customer’s account.

(i) Any Block Trade in violation of these requirements will constitute conduct which is inconsistent 

with just and equitable principles of trade.

(j) Nothing in this Rule 308 shall prohibit a Participant from executing a transaction via the Order 

Book, vRFQ procedures or as a Pre-Arranged Cross that exceeds the Appropriate Minimum Block Size. 

Such transactions will not receive treatment as Block Trades and will not be afforded a reporting time 

delay under Part 43 of the Commission Regulations.

Rule 309 Reporting and Data Collection

(a) In furtherance of Applicable Law, IGDL will capture and retain all transaction data, so as to be 

able to reconstruct all transactions within a reasonable period of time and to provide evidence of any 

Violations.
43

(b) In furtherance of Applicable Law, IGDL will retain records for all transactions executed on the 

Facility. This includes all Bids/Offers, RFQs and Pre-Arranged Crosses, whether accepted, unaccepted, 

cancelled or modified, and all acceptances of such transactions.

(c) In furtherance of Applicable Law, IGDL shall maintain an electronic transaction history database, 

which includes a history of all Bids/Offers transactions, and also includes: (i) all data that are input into 

the trade entry system; (ii) the categories of Participant or Customer for which each transaction is 

executed, including whether the Participant or Customer executed the transaction for its own account; 

(iii) timing and sequencing data adequate to reconstruct trading; and (iv) subject to Rule 309(h), 

identification of each Participant or Customer to which fills are allocated.

(d) IGDL will use the electronic transaction history database to reconstruct trading and identify 

possible Violations. In furtherance of Applicable Law, IGDL will conduct an annual review of compliance 

by all Participants and Customers that are responsible for, or in control of, the creation of audit trail 

records with its audit trail and recordkeeping requirements and will identify Participants and Customers 

that may have failed to comply with such requirements. Such Participants and Customers will be subject 

to investigation by the Market Regulation Staff for possible disciplinary action. The annual review must 

include, but is not limited to, reviews of randomly-selected samples of front end audit trail data for order 

routing systems; a review of the process by which user identifications are assigned and user identification 

records are maintained; a review of usage patterns associated with user identifications to monitor for 

violations of user identification Rules; and reviews of account numbers and Customer Type Indicator 

Codes in transaction records to test for accuracy and improper use.

(e) All such information will be maintained by IGDL in a manner that protects it from unauthorised 

alteration, as well as from accidental erasure or other loss.

(f) IGDL will publish trading information as required by:

(1) Core Principle 9, Commission Regulation § 37.901 and Part 16 of the Commission 

Regulations; and

(2) FCA rules and MAR 5.8 and 5.9.

(g) Reporting to SDRs.

(1) IGDL will report all transactions in Contracts executed on the Facility or pursuant to the 

Rules to an SDR of IGDL’s choice as soon as technologically practicable after the 

execution of such transaction. IGDL will report such transactions as set forth below:

(i) Cleared Contracts, including all legs of a Package Transaction, in all asset 

classes: IGDL reports to DTCC;

(ii) Non-Cleared Contracts, including all legs of a Package Transaction, in all asset 

classes: IGDL reports to DTCC.

With respect to Cleared Contracts, all Cleared Contracts are currently cleared by 

LCH.Clearnet, Ltd., CME or JSCC and will be reported to DTCC. With respect to NonCleared Contracts, the Facility reports all such transactions to DTCC.

(2) As soon as technologically practicable after the execution of a Contract, IGDL will report 

to both counterparties, and to the DCO, if any, that will clear the Contract: (i) the identity 

of the SDR to which the Contract was reported; and (ii) the Contract’s unique Swap 

identifier.
44

(3) All real-time data required by Part 43 of the Commission Regulations and all creation 

data, including primary economic terms and confirmation data, required by Part 45 of the 

Commission Regulations will be reported to the relevant SDR as provided for under 

Part 43 and Part 45 of the Commission Regulations.

(4) IGDL will disseminate swap transaction and pricing data relating to Contracts to 

Participants no earlier than the transmittal of such information to the relevant registered 

SDR.

(5) After becoming aware of or being notified of any errors or omissions in the transaction or 

pricing data set forth in a Confirmation by a Participant pursuant to Rule 312, the Facility 

shall then promptly submit corrected data to the relevant SDR.

(6) Neither the Facility nor any Participant may submit or agree to submit a cancelation or 

correction for the purposes of re-reporting Swap transaction and pricing data in order to 

gain or extend a delay in public dissemination of accurate Swap transaction or pricing 

data or to otherwise evade the reporting requirements of Part 43 of the CFTC 

Regulations.

(h) Post Trade Allocations.

(1) In reliance on NAL 15-68, expiring November 15, 2017, IGDL will not capture post-trade 

allocations in its audit trail data or conduct associated audit trail reviews of post-trade 

allocations.

(2) Each Participant and Customer shall provide IGDL post-trade allocation information to 

the SEF upon the request of IGDL.

(3) During the course of any trade practice surveillance or market surveillance investigation 

into any trading activity involving post-trade allocations, upon the request of the CFTC or 

otherwise, IGDL shall ascertain whether a post-trade allocation was made. Upon 

determining that such an allocation was made, IGDL shall request, obtain and review the 

post-trade allocation information as part of its investigation.

Rule 310 Bid/Offer Cancellation

(a) A Participant can submit instructions to either cancel or modify a Bid/Offer which that Participant 

has placed on the Facility if that Bid/Offer has not yet been accepted. Upon receipt of instructions to 

cancel a Bid/Offer that has not been executed, a Trading Platform will withdraw the Bid/Offer and confirm 

the cancellation of the Bid/Offer. If a Participant modifies a Bid/Offer that has not been executed, IGDL 

will treat the modified Bid/Offer as a new Bid/Offer.

(b) IGDL will attempt to cancel or modify an existing Bid/Offer after a Participant enters a cancellation 

or modification instruction. However, the Bid/Offer may be executed before IGDL is able to cancel or 

modify it. If a Bid/Offer has been filled in whole or in part, a Participant may modify or cancel only that 

portion of the Bid/Offer (if any) that has not been executed. Once cancelled by IGDL, a Bid/Offer will not 

be executed.

(c) Upon suspension or revocation of a Participant’s trading privileges by IGDL, any unaccepted 

Bid/Offer on the Facility for such Participant shall be cancelled by IGDL.

Rule 311 [Reserved]
45

Rule 312 Enforceability of Transactions

(a) Settlement

(1) Each Participant or, where a transaction is on behalf of a Customer, the relevant 

Customer, is obligated to settle all transactions executed, pursuant to the Rules in this 

Chapter 3.

(2) A transaction executed on the Facility or subject to the Rules shall not be void, voidable, 

subject to rescission, otherwise invalidated or rendered unenforceable as a result of:

(i) a violation by the Facility of Section 5h of the Act or Part 37 of the Commission 

Regulations;

(ii) any Commission proceeding to alter or supplement a rule, term or condition 

under Section 8a(7) of the Act or to declare an emergency under Section 8a(9) of 

the Act; or

(iii) any other proceeding the effect of which is to: (A) alter or supplement a specific 

term or condition or trading rule or procedures; or (B) require the Facility to adopt 

a specific term or condition, trading rule or procedure, or to take or refrain from 

taking a specific action.

(b) Issuance of Facility Confirmations for Cleared Contracts. Participants and Customers are 

obligated to submit for clearing all Contracts so required by the Act, Commission Regulations and any 

other applicable law. For Cleared Contracts, IGDL will provide the Trading Privilege Holder a 

Confirmation of all the terms of each transaction executed on the Facility at the time of execution; 

provided that where a Trading Privilege Holder is a Customer in an Intermediated Transaction, the 

confirmation will be provided to the Intermediary in accordance with Rule 313(c). The Confirmation 

provided by IGDL for Cleared Contracts will be the final legally binding confirmation of the terms of any 

transaction executed on the Facility and will supersede any conflicting confirmation or agreement 

provided to, or between, as applicable, Participants and Customers, regardless of when such other 

confirmation is provided.

(c) Issuance of Facility Confirmations for Uncleared Transactions

(1) The economic terms specific to the transaction agreed by each Participant and/or 

Customer on the Facility with respect to an uncleared transaction shall be reflected by the 

Facility in a written communication (the “Trade Communication”) issued to each 

applicable Participant and/or Customer at the time of execution of the uncleared 

transaction. The Trade Communication, together with the documents and agreements 

(including, without limitation, ISDA master agreements, other master agreements, terms 

supplements, master confirmation agreements, and incorporated industry definitions) 

governing such transaction existing at the time of such commitment to which each

Participant and/or Customer are party (the “Terms Incorporated by Reference”) shall, 

taken together, for purposes of Commission Regulation 37.6(b), comprise all of the terms 

of such transaction and serve as the Confirmation of such transaction.

(2) In satisfaction of the obligations imposed on IGDL under Commission Regulation 37.6(b), 

(i) each Trade Communication is deemed to incorporate the Terms Incorporated by 

Reference set forth in this Rule 312(c) upon issuance of the Trade Communication, 

(ii) each Participant and Customer hereby agrees that the provisions of Rule 312(c)(3)

shall govern any conflicting terms, and (iii) the resulting Confirmation takes place at the 

time of execution of, and contains all the terms of, the transaction.
46

(3) In the event of any conflict between (x) the Trade Communication and (y) the Terms 

Incorporated by Reference, the Trade Communication shall prevail to the extent of any 

inconsistency and each Trade Communication shall state the same.

(4) In accordance with NAL 17-17, expiring on the effective date of revised Commission 

regulations governing SEF confirmation procedures, upon the request of IGDL, each 

Participant and Customer shall provide copies of the Terms Incorporated by Reference to 

IGDL.

(5) In accordance with NAL 17-17, expiring on the effective date of revised Commission 

regulations governing SEF confirmation procedures, upon the request of the 

Commission, IGDL shall request the Terms Incorporated by Reference from the relevant 

Participant or Customer and shall provide such Terms Incorporated by Reference to the 

Commission as soon as possible after receipt from the Participant or Customer.

(6) Review of Confirmations. Each Participant shall review the contents of each 

Confirmation issued to it pursuant to this Rule 312 and shall promptly report any errors or 

omissions in the transaction or pricing data therein to the counterparty to the Contract. 

Each Participant that is the reporting counterparty for such Contract, as determined 

pursuant to Rule 316, shall report all such errors or omissions to the Facility as soon as 

technologically practicable after becoming aware of the errors or omissions.

Rule 313 Intermediated Transactions

(a) Subject to Rule 305(a)(6), Participants who are Intermediaries shall immediately enter into a 

Trading Platform all executable Orders received by telephone from their Customers, and shall 

immediately submit all RFQs and Pre-Arranged Crosses to an Execution Specialist. If an Order, RFQ or 

Pre-Arranged Cross cannot be immediately entered into a Trading Platform or submitted to an Execution 

Specialist, as applicable, an electronic record which includes the account identifier that relates to the 

account owner, time of receipt, and terms of the Order, RFQ or Pre-Arranged Cross must immediately be 

created, and the Order, RFQ or Pre-Arranged Cross must be entered into a Trading Platform or submitted 

to an Execution Specialist as soon as practicable.

(b) Priority of execution. Non-discretionary executable Customer Orders received by a Participant 

who is an Intermediary shall be entered into Facility in the sequence received. Non-discretionary Orders 

that cannot be immediately entered must be entered when the Orders become executable, in the 

sequence in which the Orders were received.

(c) IGDL shall provide all Confirmations of Intermediated Transactions to the Intermediary upon 

execution of the transaction. Except to the extent that IGDL sends Confirmations of Contracts directly to 

the relevant Customer, any Participant that transacts as an Intermediary for any Customer shall be 

responsible for ensuring that such Customers receive all Confirmations of Contracts entered into on 

behalf of such Customers as soon as technologically practicable after receipt of the Confirmation from 

IGDL.

Rule 314 Bunched Orders

Bunched Orders must be allocated and recorded in accordance with Commission Regulation 1.35(b)(5) 

and the NFA’s Interpretive Notice related to Compliance Rule 2-10. Bunched Orders may be entered 

using a designation for a group of accounts or suspense account number; provided, however that:

(1) the Bid/Offer or Pre-Arranged Cross is being placed by a Participant who is, or is acting 

on behalf of, an account manager for multiple accounts eligible for post execution 

allocation; or
47

(2) a written, pre-determined allocation scheme that defines the group of accounts has been 

provided to the Clearing Firm accepting or clearing the Bid/Offer or Pre-Arranged Cross 

prior to the time that such Bid/Offer or Pre-Arranged Cross is entered.

Rule 315 IGDL Authority over Transactions

(a) IGDL Authority Regarding Cancellations, Price Adjustments and New or Offsetting Transactions

IGDL has authority to cancel any transaction or adjust the price of any transaction executed on the 

Facility, or to execute or require the execution of a new or offsetting transaction: (i) when IGDL 

determines in its sole discretion such action is necessary to mitigate market disrupting events caused by 

the improper or erroneous use of a Trading Platform or by system defects; (ii) at any time IGDL 

determines, in its sole discretion, that allowing a transaction to stand as executed may have a material 

adverse effect on the integrity of the market; or (iii) in accordance with Rule 204(h), Rule 315(c), 

Rule 315(d), Rule 315(h), or Rule 315(i). All decisions of IGDL regarding IGDL’s cancellation of 

transactions or the adjustment of transaction prices and the execution of new or offsetting transactions 

shall be final, subject to Rule 315(d).

(b) Determination to Review a Transaction’s Price

(1) IGDL may determine to review a transaction’s price based on its independent analysis of 

market activity or upon a Participant’s request. A Participant’s request for review must be 

made (i) for an uncleared Pre-Arranged Cross, within one (1) Business Day of the 

execution of such transaction and (ii) for any other transaction executed on the Facility, 

within 5 minutes of the execution of such transaction. In the absence of a timely request 

for review, IGDL may determine whether or not a transaction will be subject to review in 

its sole discretion. Notwithstanding the foregoing, subject to Applicable Law, IGDL shall 

amend the terms of, or cancel, any transaction that the parties, together with the DCO, as 

applicable, mutually agree to amend or cancel, in the event that such amendment or 

cancellation is not submitted to IGDL within the applicable review period specified above.

(2) If IGDL determines to review a transaction’s price, it will promptly issue an alert to all 

Participants via a Trading Platform or electronic mail indicating that the transaction is 

under review.

(c) Review of a Transaction’s Price

(1) In reviewing a transaction’s price, IGDL will first determine whether the price of the 

transaction is in the Non-Reviewable Range.

(2) In applying the Non-Reviewable Range, IGDL shall determine the fair value price for the 

Swap at the time the transaction under review occurred. IGDL may consider any relevant 

information, including, but not limited to, the last transaction price of the Swap or a better 

Bid/Offer, a more recent price for a different maturity date, the price of the same or 

related Swap established in another venue or another market, the market conditions at 

the time of the transaction, the theoretical value of an Option based on the most recent 

implied volatility and responses to an RFQ.

(3) If IGDL determines that the price of a transaction is inside the Non-Reviewable Range, 

IGDL will issue an alert indicating that the transaction shall stand as executed.

(4) If IGDL determines that the price of a transaction is outside the Non-Reviewable Range, 

IGDL shall have the right, in its sole discretion, to cancel or adjust the price of such 

transaction.
48

(5) The method of adjustment or cancellation of any Cleared Contract that is adjusted or 

cancelled pursuant to Rule 315(c)(4) shall be the method provided for by the rules and 

procedures of the relevant DCO.

(d) Alternative Resolution by Agreement of Parties for Transactions Reviewed for Price

(1) With the approval of IGDL, parties to a transaction that is under review for price or that 

has had its price adjusted may instead, together with the DCO, as applicable, mutually 

agree to cancel or otherwise adjust the price of the transaction.

(2) With the approval of IGDL, parties to a transaction that is cancelled may instead, together 

with the DCO, as applicable, mutually agree to adjust the price of such transaction to a 

price within the Non-Reviewable Range.

(3) Subject to sections (d)(1) and (d)(2), parties to a transaction that is cancelled or that has 

had its price adjusted may mutually agree to a cash adjustment.

(4) Any cancellation or adjustment made pursuant to sections (d)(1), (d)(2) or (d)(3) must be 

reported to the Facility by the parties within one (1) Business Day and the parties must 

maintain a record of such adjustment.

(e) Liability for Losses Resulting from Cancellations or Price Adjustments

(1) A party that through error or mistake enters a Bid/Offer, RFQ or Pre-Arranged Cross that 

results in a cancellation or price adjustment shall be responsible for demonstrated claims 

of realised losses incurred by persons whose transaction prices were cancelled or 

adjusted; provided, however, that a claimant shall not be entitled to compensation for 

losses incurred as a result of the claimant’s failure to take reasonable actions to mitigate 

the loss.

(2) A claim for a loss pursuant to this Rule 315 must be submitted to the Facility within one 

(1) Business Day of the event giving rise to the claim. IGDL will reject any claim that is 

not filed in a timely manner and such decision shall be final. Eligible claims shall be 

forwarded by IGDL to the party responsible for the Bid/Offer, RFQ or Pre-Arranged Cross 

that resulted in a cancellation or a price adjustment of a transaction and the Participant 

through which the transaction was submitted to the Facility. Such party, or Participant on 

behalf of such party, shall, within ten (10) Business Days of receipt of the claim, admit or 

deny responsibility in whole or in part. Failure to respond to the claim within ten 

(10) Business Days shall be deemed a denial of liability.

(3) To the extent that liability is admitted, payment shall be made within ten (10) Business 

Days. Unless otherwise agreed upon in writing by the parties, failure to make the 

payment within ten (10) Business Days shall be deemed a denial of liability for the 

purposes of this Rule 315. A copy of any such written agreement must be provided to 

IGDL.

(4) To the extent that liability is denied, the party making the claim may submit the claim for 

arbitration pursuant to Rule 702. Such claims must be submitted to IGDL within ten 

(10) Business Days of the date the party was issued notification that liability was denied.

(f) The Non-Reviewable Ranges for all Swaps listed on the Facility are as follows:

(1) Outright Contracts: Less than +/- 1.5 basis points.
49

(2) Package Transactions and individual components of Implied Package Transactions: 

Less than +/- 1.0 basis point.

(g) Records of Cancellations and Price Adjustments

(1) Cancelled transactions and any prices that have been adjusted shall be cancelled in 

IGDL’s official records.

(2) Transactions that have had their price adjusted shall be reflected in IGDL’s official 

records at the adjusted price.

(h) Review of Transactions for Errors

(1) If a Participant, Customer or Clearing Firm believes that any transaction in one or more 

Contracts was executed, cleared or rejected for clearing as a result of an Error, as 

defined in Rule 315(h)(3), such person may request review of the transaction.

(2) Upon receipt of a request for review of a transaction, or if IGDL determines on its own 

initiative to conduct such a review, IGDL will review its records to determine if an Error 

occurred.

(3) IGDL may cancel or adjust the transaction, or execute or require the execution of a new 

or offsetting Cleared Contract under the procedures of Rule 315(i), as appropriate, if the 

review described in this Rule reveals that:

(i) a Trading Platform or an Execution Specialist made a material mistake or that a 

mistake occurred as a result of a malfunction in a Trading Platform or by human 

error;

(ii) a Bid/Offer or RFQ or Pre-Arranged Cross was incorrectly displayed and/or 

executed and/or reported;

(iii) a Trading Platform, an Execution Specialist, Participant or Customer made a 

clerical or operating error or omission that caused a transaction to be rejected 

from clearing and void ab initio; or

(iv) a Clearing Firm or DCO rejected a leg of a Package Transaction for clearing 

because of the sequencing of submission for clearing of the legs of the 

applicable Package Transaction (each of the foregoing, an “Error”).

(4) If the review described in this Rule reveals that no Error occurred, IGDL will inform any 

person who requested the review that IGDL has determined that the transaction was 

properly handled, the evidence supporting that determination, and that a cancelation, 

adjustment or a new or offsetting transaction under Rule 315(i) will not be made.

(5) IGDL will document in writing all requests for review of transactions received by IGDL, or 

any review on its own initiative, the time and manner in which IGDL reviewed its 

electronic audit trail in response to the request or review on its own initiative, the outcome 

of that review, and the action or actions taken by IGDL in response to that review.

(6) If a transaction is reviewable for price under Rule 315(b), the procedures of this 

Rule 315(h) shall not apply.
50

(i) Procedures for Correcting Errors

(1) The procedures of this Rule 315(i) are in accordance with NAL 17-27, expiring on the 

effective date of revised Commission regulations governing swaps with clerical and 

operational errors executed on a swap execution facility, and are limited to:

(i) A Cleared Contract that was rejected for clearing and void ab initio because of a 

clerical or operational error or omission by IGDL, a Participant or a Customer 

(each, a “Rejected Transaction”),

(ii) A leg of a Package Transaction that was rejected for clearing because of the 

sequencing of submission for clearing of the legs of the applicable Package 

Transaction and only for such rejected leg (each, a “Rejected Leg”), and

(iii) A Cleared Contract that is carried on a DCO’s books as a result of a clerical or 

operational error or omission by IGDL, a Participant or a Customer that was not 

identified until after the Cleared Contract had been cleared (each, an 

“Erroneously Cleared Transaction”),

in each case where the Facility has affirmatively determined that the transaction or a term 

thereof resulted from an Error.

(2) For Rejected Transactions and Rejected Legs, if a Participant, Customer or Clearing Firm 

believes that a transaction qualifies as a Rejected Transaction or a Rejected Leg, such 

Participant, Customer or Clearing Firm shall request review of the transaction pursuant to 

Rule 315(h).

(i) Upon completion of the review of the transaction pursuant to Rule 315(h), if IGDL 

determines that an Error resulted in a Rejected Transaction or a Rejected Leg 

and:

A. If IGDL is able to determine how to correct the Error, IGDL shall execute 

a new Cleared Contract with the same terms as the Rejected 

Transaction or Rejected Leg, other than the Error, without obtaining 

consent of the Participant that submitted the Rejected Transaction or 

Rejected Leg or the Customer on whose behalf such transaction was 

submitted. The new Cleared Contract must be submitted by an 

Execution Specialist as a Pre-Arranged Cross, and such Pre-Arranged 

Cross shall be subject to pre-execution credit check and risk screening 

pursuant to Rule 204(b).

B. If IGDL is unable to determine how to correct the Error, IGDL shall 

consult with the Clearing Firms for the Rejected Transaction or Rejected 

Leg and the Participants and Customers involved in such transaction, as 

necessary, and the Clearing Firms for such transactions may, with the 

consent of each respective Customer or Participant, agree to a new 

Cleared Contract with the same terms as the rejected Cleared Contract, 

other than the Error. Such Customer or Participant consent may not be 

obtained in advance, and must be sought and obtained by each Clearing 

Firm on a case-by-case basis, after the Cleared Contract has been 

rejected. If there is such agreement and consent, the new Cleared 

Contract must be submitted by the Participant specified in Rule 304(b) as 

a Pre-Arranged Cross pursuant to the procedure in Rule 304(b), and 

such Pre-Arranged Cross shall be subject to pre-execution credit check 

and risk screening pursuant to Rule 204(b).
51

(ii) Upon execution of such Pre-Arranged Cross by IGDL to replace a Rejected 

Transaction or Rejected Leg, IGDL shall submit the transaction to the DCO for 

clearing as quickly as technologically practicable, but in any case no later than 

60 minutes from the issuance of the notice of rejection by the DCO to the 

Clearing Firms.

(iii) If the new Cleared Contract resulting from such Pre-Arranged Cross is rejected 

from clearing, it is void ab initio and no additional new Cleared Contract will be 

permitted to be submitted under the procedure in this Rule 315(i)(2).

(iv) IGDL shall report Swap transaction data to the relevant SDR pursuant to 

Rule 309(f) for a new Cleared Contract that clears with the same terms as the 

Rejected Transaction or Rejected Leg, as applicable, other than the Error, 

including: a Part 43 cancellation for the original transaction, a Part 45 

termination indicating the original transaction is void ab initio, and swap 

transaction data pursuant to Parts 43 and 45 for the new Cleared Contract. Such 

data shall reference the original cancelled trade, indicate that it has been 

reported pursuant to the procedures described in this Rule 315(i)(2) and link the 

original cancelled trade to the new trade for reporting to the relevant SDR under 

Part 43 and Part 45 of the Commission Regulations.

(v) The procedures in this Rule 315(i)(2) are not available for Rejected Legs of 

Package Transactions that are rejected for clearing by a Clearing Firm or DCO 

because the Package Transaction as a whole failed to satisfy the applicable 

Risk-Based Limits.

(3) For Erroneously Cleared Transactions, if a Participant, Customer or Clearing Firm 

believes that a Cleared Contract is carried on the books of a DCO as a result of an Error, 

such Participant, Customer or Clearing Firm may request review of the transaction 

pursuant to Rule 315(h).

(i) Upon completion of the review of the transaction pursuant to Rule 315(h), if IGDL 

determines that an Error resulted in an Erroneously Cleared Transaction and:

A. If IGDL is able to determine how to correct the Error, IGDL shall execute 

a Cleared Contract that offsets the Erroneously Cleared Transaction 

carried on the books of the relevant DCO through the same Clearing 

Firms that cleared the Erroneously Cleared Transaction and IGDL shall 

execute a new Cleared Contract with the same terms as the Erroneously 

Cleared Transaction, other than the Error, in each case without obtaining 

consent of the Participant that submitted the Erroneously Cleared 

Transaction or the Customer on whose behalf such transaction was 

submitted; provided that, where an Erroneously Cleared Transaction did 

not satisfy the Risk-Based Limits of a Participant’s Clearing Firm, IGDL 

shall obtain the consent of the relevant Clearing Firm prior to executing 

such offsetting Cleared Contract. The new Cleared Contract must be 

submitted by an Execution Specialist as a Pre-Arranged Cross, and such 

Pre-Arranged Cross shall be subject to pre-execution credit check and 

risk screening pursuant to Rule 204(b).

B. If IGDL is unable to determine how to correct the Error, IGDL shall 

consult with the Clearing Firms for Erroneously Cleared Transactions 

and the Participants and Customers involved in such transaction, as 

necessary, and the relevant Customer or Participant may agree to 

execute a Cleared Contract that offsets the Erroneously Cleared 

Transaction carried on the books of the relevant DCO through the same 
52

Clearing Firms that cleared the Erroneously Cleared Transaction and to 

execute to a new Cleared Contract with the same terms as the rejected 

Cleared Contract, other than the Error. The new Cleared Contracts must 

be submitted by the Participant specified in Rule 304(b) as Pre-Arranged 

Crosses pursuant to the procedure in Rule 304(b), and such 

Pre-Arranged Crosses shall be subject to pre-execution credit check and 

risk screening pursuant to Rule 204(b).

(ii) Upon execution of such Pre-Arranged Crosses by IGDL to offset an Erroneously 

Cleared Transaction and to enter into a new Cleared Contract, IGDL shall submit 

the transactions to the DCO for clearing as quickly as technologically practicable, 

but in any case no later than three days after the Erroneously Cleared 

Transaction was executed.

(4) For the avoidance of doubt, the procedures of this Rule 315(i) are not applicable to any 

transaction rejected by a DCO for credit reasons.

Rule 316 Reporting Counterparty

(a) For each Contract executed on or subject to the Rules, IGDL shall report all required data to an 

SDR in accordance with Rule 309, and shall include in such creation data the identification of the 

reporting counterparty. The reporting counterparty will be determined by IGDL, if possible, in accordance 

with Commission Regulation 45.8(a) – (f) and in the event the counterparties to the Contract are of the 

same hierarchy level, the ISDA Reporting Party Rules, the relevant portion of which is attached to this 

Rulebook as Annex 1, and identify to the counterparties which is the reporting counterparty. If IGDL is 

unable to determine the reporting counterparty in accordance with Commission Regulation 45.8(a) - (f) 

and the ISDA Reporting Party Rules, IGDL will identify the buyer of the Contract as the reporting 

counterparty in the creation data. By executing the Contract on the Facility, the counterparties agree to 

the use of the ISDA Reporting Party Rules and where necessary, the identification of the buyer as 

reporting counterparty, and waive the opportunity to agree separately upon a reporting counterparty and 

to receive notice from IGDL, as provided in Commission Regulation 45.8(d) and 45.8(f).

(b) [NOT USED]

(c) For each Contract executed on or subject to the Rules, the reporting counterparty and/or the 

relevant DCO is responsible for reporting continuation data to the SDR to which the creation data for the 

Contract was first reported in accordance with Commission Regulations 45.4 and 45.10.
53

CHAPTER 4

TRADING STANDARDS

Rule 401 Fraudulent Statements and Acts

(a) No Participant or Customer shall make or attempt to make any untrue or misleading statement of 

a material fact or to omit to state a material fact necessary in order to make the statements made not 

untrue or misleading, in connection with or related to any transaction on or other activity related to IGDL 

or the Facility.

(b) No Participant or Customer may engage in or attempt to engage in any fraudulent act, or engage 

in or attempt to engage in any manipulative device, scheme or artifice to cheat, defraud or deceive, in 

connection with or related to any transaction on or other activity related to IGDL or the Facility.

Rule 402 Abusive Trading Practices

(a) No Participant or Customer shall create fictitious or wash transactions on the Facility or execute 

any Bid/Offer for a fictitious or wash transaction with knowledge of its nature.

(b) No Participant or Customer shall engage in trading on the Facility or subject to the Rules for the 

purpose of passing money or transferring equity from one account to another.

(c) No Participant trading as an Intermediary on behalf of a Customer shall engage in trading ahead 

of a Customer Order, trading against a Customer Order without the Customer’s consent, front running a 

Customer Order, accommodation trading or improper cross trading.

Rule 403 Good Faith Bids/Offers and RFQs

(a) A Participant or Customer shall not knowingly enter, or cause to be entered, a Bid/Offer or RFQ 

into the Facility other than in good faith for the purpose of executing bona fide transactions.

(b) A Participant or Customer shall not knowingly enter, or cause to be entered, a Bid/Offer or RFQ 

unless such Participant or Customer has sufficient funds to provide the required collateral for the related 

Contract should the Contract be executed.

Rule 404 Pre-Execution Discussions and Pre-Arranged Transactions

No Participant or Customer shall prearrange or pre-negotiate or non-competitively execute any 

transaction on the Facility except as follows:

(a) Block Trades are not subject to this prohibition.

(b) Permitted Transactions executed pursuant to Rule 304 are not subject to this prohibition.

(c) Participants and Customers may engage in pre-execution discussions with regard to transactions 

executed on the Facility in accordance with Rule 305(a)(7); provided, however, that:

(1) A party may not engage in pre-execution communications with other market participants 

on behalf of another party unless the party for whose benefit the transaction is being 

made has previously consented to permit such communications.

(2) Parties to pre-execution communications shall not:

(i) disclose to a non-party the details of such communications; or
54

(ii) enter a Bid/Offer to take advantage of information conveyed during such 

communications except in accordance with this Rule.

(3) Notwithstanding paragraph (c)(2) of this Rule, a party may disclose or use such 

communications if such disclosure or use is authorised in writing by the counterparty, or 

is necessary:

(i) for the effective execution of any Swap for or with the counterparty;

(ii) to hedge or mitigate any exposure created by such Swap; or

(iii) to comply with a request of the Commission, the U.S. Department of Justice, any 

self-regulatory organisation, or an applicable prudential regulator, including but 

not limited to the FCA, or as otherwise required by law.

(d) Where a transaction is executed pursuant to Rule 315(i), communications concerning such 

transaction shall not be considered pre-execution communications prohibited by this Rule 404.

Rule 405 Manipulation and Price Distortion

(a) Any manipulation or attempted manipulation of the price of any Contract is prohibited.

(b) Bids/Offers entered into a Trading Platform or Pre-Arranged Crosses submitted to an Execution 

Specialist for the purpose of upsetting the equilibrium of the market in any Contract or creating a condition 

in which prices do not or will not reflect fair market values are prohibited and it shall also be prohibited for 

any Participant or Customer to make or assist in entering any such Bid/Offer or Pre-Arranged Cross with 

knowledge of the purpose thereof or, with such knowledge, to assist in carrying out any plan or scheme 

for the entering of any such Bid/Offer or Pre-Arranged Cross.

(c) Any other manipulative and disruptive behaviour not otherwise prohibited by the Rules is 

prohibited to the extent prohibited by the Act or Commission Regulations, including but not limited to 

Sections 6(c)(1) and (3), 9(a)(2), 4c(a)(5)(A) and (C) of the Act and Commission Regulations 180.1(a) and 

180.2.

Rule 406 Disruptive Trading Practices

(a) No Participant or Customer shall enter or cause to be entered any Bid/Offer or other message 

with the intent to:

(1) mislead other Participants;

(2) overload, delay, or disrupt the Order Book or any other systems of the Facility or other 

Participants; and

(3) disrupt the orderly conduct of trading or the fair execution of transactions.

(b) No Participant or Customer shall engage in any trading, practice or conduct on the Facility or 

subject to the Rules that (1) violates Bids/Offers; (2) demonstrates intentional or reckless disregard for the 

orderly execution of transactions during the closing period; (3) is, is of the character of, or is commonly 

known to the trade as, “spoofing” (entering a Bid/Offer with the intent to cancel the Bid/Offer before 

execution); or (4) is any other manipulative or disruptive trading practice prohibited by the Act or

Commission Regulations.
55

Rule 407 General Offences

It will be an offence for a Participant or Customer to:

(a) violate any Rule regulating the conduct or business of a Participant or Customer or any 

agreement made with IGDL;

(b) engage in any act detrimental to IGDL’s operations or self-regulatory function or IGDL’s ability to 

enforce its Rules or is detrimental to the interest or welfare of the Facility;

(c) fail to observe the proper standards of conduct expected of market participants;

(d) engage in any conduct which tends to impair the dignity or good name of the Facility;

(e) engage in conduct inconsistent with just and equitable principles of trade;

(f) engage in dishonourable or uncommercial conduct;

(g) aid or abet the commission of any Violation by another person;

(h) fail to supervise its employees or agents in the conduct of the Participant’s or Customer’s 

business related to the Facility; and

(i) engage in conduct in violation of Applicable Law or the rules of any DCO which clears a Cleared 

Contract in connection with or related to any transaction on or other activity related to the Facility.

Rule 408 Position Limits and Position Accountability

(a) To reduce the potential threat of market manipulation or congestion, the Facility shall adopt for 

each Contract, as is necessary and appropriate, Position Limits or position accountability levels for 

speculators.

(b) IGDL hereby adopts the Commission’s Position Limits for any Contract for which the Commission 

has adopted a Position Limit. In no event will IGDL set its Position Limits at a level higher than the 

Commission’s Position Limits.

(c) For Permitted Transactions, IGDL may set and enforce position accountability levels or send the 

Commission a list of the Permitted Transactions transacted on the Facility.

(d) All Participants and Customers must comply with all IGDL and Commission requirements 

regarding Position Limits or position accountability levels.

(e) Each Participant required to file any report, statement, form or other information with the 

Commission pursuant to Commission Regulations concerning a Position Limit on any Contract or 

commodity underlying a Contract must simultaneously file a copy of such report, statement, form or other 

information with IGDL. Such information shall include, for Participants who are Intermediaries, 

information concerning the Customers for which transactions are made on the Facility.

(f) Any Participant or Customer who exceeds an IGDL or Commission Position Limit by entering into 

a transaction on the Facility shall be deemed in Violation. In addition, any Participant or Customer 

entering bids or offers, if accepted, which would cause that Participant or Customer to exceed the 

applicable IGDL or Commission Position Limit, shall be in Violation.

(g) Without limiting any provision of these Rules, IGDL shall have the authority to obtain from any 

Participant or Customer, on request, information with respect to all positions of such Participant or 
56

Customer in Contracts which are equivalent, for purposes of IGDL or Commission Position Limits, to 

those transacted in by the Participant on the Facility.
57

CHAPTER 5

RULE ENFORCEMENT

Rule 501 Jurisdiction

(a) IGDL shall have the authority to initiate and conduct investigations, and prosecute Violations 

committed by Facility Subject Persons, and to impose sanctions for such Violations as provided in these 

Rules.

(b) Each Participant and Clearing Firm, upon becoming a Participant or Clearing Firm and thereafter 

upon any change of address shall file with IGDL a written notice designating an address for receiving 

service of documents. If a Participant or Clearing Firm fails to designate such an address, service by mail 

to its address on file with IGDL shall be good service, and delivery thereof shall be deemed to have 

occurred as of the date of such mailing.

Rule 502 Facility Market Regulation Staff Powers and Duties

(a) It shall be the duty of the Compliance Function to enforce these Rules, and shall have the 

authority to inspect the books and records of all Facility Subject Persons and the authority to require any 

Facility Subject Person to appear before it to answer questions regarding matters being investigated by 

the Market Regulation Staff. The Compliance Function may also delegate such authority to Market 

Regulation Staff who shall consist of personnel of IGDL, and such other Regulatory Services Providers as 

IGDL may hire on a contract basis. The Compliance Function shall ensure that surveillance systems are 

established to monitor trading to prevent manipulation and price distortion. Such monitoring may be done 

by the Market Regulation Staff or a third party provider, and shall include real time monitoring and the 

ability to conduct comprehensive and accurate transaction reconstructions.

(b) The Market Regulation Staff shall conduct investigations of possible Violations, prepare written 

reports respecting such investigations, furnish such reports to the Review Panel and conduct the 

prosecution of such Violations. An investigation must be commenced upon receipt of a request from any 

Regulatory Agency, its staff or receipt of information (such as data produced by automated surveillance 

systems) by IGDL that in the judgment of the Market Regulation Staff indicates a reasonable basis for 

finding that a Violation may have occurred or will occur. Absent mitigating factors, each investigation will 

be completed no later than 12 months after the investigation is opened. Mitigating factors include the 

complexity of the investigation, the number of firms or individuals involved as potential wrongdoers, the 

number of potential Violations to be investigated and the volume of documents and data to be examined 

and analysed by Market Regulation Staff.

(c) If, in any case, the Compliance Function or another member of the Market Regulation Staff, 

designated for this purpose by the Compliance Function, concludes that there is a reasonable basis for 

finding a Violation, he or she shall (i) present an investigation report concerning the matter to the Review 

Panel or (ii), in the case of Violations subject to Rule 516, proceed in accordance with Rule 516. The 

investigation report must include the reason the investigation was initiated; a summary of the complaint, if 

any; the relevant facts; Market Regulation Staff’s analysis and conclusions; and a recommendation as to 

whether disciplinary action should be pursued. The report may also include the Facility Subject Person’s 

disciplinary history at the Facility, including copies of any warning letters. The Market Regulation Staff 

may issue a warning letter, including for minor transgressions. However, no more than one warning letter 

may be issued to the same person found to have committed the same Violation more than once in a 

rolling 12-month period.

(d) If, in any case, the Compliance Function or another member of the Market Regulation Staff, 

designated for this purpose by the Compliance Function, concludes that no reasonable basis exists for 

finding a Violation, he or she must prepare a written investigation report including the reason the 

investigation was initiated; a summary of the complaint, if any; the relevant facts; and Market Regulation 
58

Staff’s analysis and conclusions. The Compliance Function or another member of the Market Regulation 

Staff may issue a warning letter in any case where it is concluded that no reasonable basis exists for 

finding a Violation, without limitation on the number of warning letters issued to a person.

(e) Before presenting an investigation report to the Review Panel, the Market Regulation Staff may, 

in its sole discretion, inform the prospective Respondent that it intends to submit the matter to the Review 

Panel, and at such time the proposed Respondent may submit an offer of settlement to the Hearing 

Panel, in accordance with the procedures of Rule 509, prior to presentation of the investigation report to 

the Review Panel.

(f) IGDL has contracted with NFA to act as Regulatory Services Provider to provide certain 

regulatory services to IGDL, including reviews of the Facility’s audit trail information for potential 

Violations. IGDL will retain ultimate decision-making authority with respect to any regulatory services to 

be provided by NFA.

(g) IGDL or its Regulatory Services Provider shall have the right with such prior reasonable advance 

notice as is practicable under the circumstances (unless in furtherance of regulatory purposes in which 

case without prior notice to Facility Subject Persons), in connection with determining whether all Rules 

are being, will be, or have been complied with by the Facility Subject Person, to: (i) inspect systems, 

equipment and software of any kind operated by the Facility Subject Person in connection with accessing, 

and the Facility Subject Person’s transacting on, the Facility, wherever located; (ii) access, either 

physically or electronically, the systems, equipment, software, and the premises on which the systems, 

equipment, and software are located, any data stored in any of the systems or equipment, during the 

regular business hours; and/or (iii) copy or reproduce any data to which IGDL has access under this Rule. 

Each Facility Subject Person shall provide the Regulatory Services Provider with the same access to its 

books and records and offices as it is required to provide to IGDL under the Rules and Applicable Law.

Rule 503 The Review Panel

(a) The Review Panel shall have the power to direct that an investigation of any suspected Violation 

be conducted by the Market Regulation Staff, and shall hear any matter referred to it by the Market 

Regulation Staff regarding a suspected Violation.

(b) The Review Panel shall be appointed by the Board, and shall be comprised of five persons, 

including at least two Participants and at least two non-Participants. In the case where the subject of the 

investigation is a Clearing Firm, at least one member of the Review Panel shall be a Clearing Firm. The 

Board shall appoint as chairman (the “Review Panel Chairman”) of the Review Panel a person who 

would not be disqualified from serving as a “Public Director” as defined in Commission Regulations. 

Three panel members shall constitute a quorum for any action, so long as they are in attendance at the 

time of the relevant action. The Review Panel may not include any members of the Market Regulation 

Staff, any person involved in adjudicating any other stage of the same Proceeding, or any person with a 

history of disciplinary offenses that would be disqualifying under CFTC Regulation § 1.63(c). The Review 

Panel shall include at least one member that is not a member of IGDL whenever the Review Panel is: 

(i) acting with respect to a disciplinary action in which the Respondent is a member of the Board, the 

Review Panel or the Hearing Panel; or (ii) when the suspected Violation involves manipulation (or 

attempted manipulation) of the price of a Contract or conduct which directly results in financial harm to a 

non-member of IGDL. The Review Panel shall include sufficient different membership interests so as to 

ensure fairness and to prevent special treatment or preference for any person.

(c) All information, records, and documents provided to the Review Panel, and all related records 

and documents shall be treated as confidential and shall not be disclosed, except as necessary to further 

an IGDL investigation or as required by Applicable Law.

(d) Upon receipt of an investigation report, the Review Panel shall promptly review the report and, 

within thirty (30) days of receipt, take one of the following actions:
59

(1) If the Review Panel determines that additional investigation or evidence is needed, it 

shall promptly direct the Market Regulation Staff to conduct further investigation;

(2) If the Review Panel determines that no reasonable basis exists for finding a Violation or 

that prosecution is otherwise unwarranted, it may direct that no further action be taken. 

Such determination must be in writing and must include a written statement setting forth 

the facts and analysis supporting the decision; or

(3) If the Review Panel determines that a reasonable basis exists for finding a Violation and 

adjudication is warranted, it must direct that the Facility Subject Person alleged to have 

committed the Violation be served with a notice of charges as set forth in Rule 504.

(e) If the Review Panel determines that there may have been a Violation but that no adjudication is 

warranted, the Review Panel may issue a warning letter to the Facility Subject Person informing it that 

there may have been a Violation and that such continued activity may result in disciplinary sanctions. 

Where a Violation is determined to have occurred, no more than one warning letter for the same potential 

Violation may be issued to the same person during a rolling 12 month period.

Rule 504 Notice of Charges

(a) If the Review Panel determines that a reasonable basis exists for finding a Violation and 

adjudication is warranted, the Compliance Function shall serve a notice of charges (a “Notice”) on the 

Facility Subject Person alleged to have been responsible for the Violation (such Facility Subject Person, 

the “Respondent”). Such Notice shall state:

(1) the acts, practices or conduct with which the Respondent is charged;

(2) the Rules allegedly violated and how such acts, practices or conduct constitute a 

Violation of such Rules;

(3) that the Respondent is entitled, upon written request filed with IGDL, within twenty 

(20) days of service of the Notice, to a formal hearing on the charges;

(4) that the failure of the Respondent to request a hearing within twenty (20) days of service 

of the Notice, except for good cause shown, shall be deemed a waiver of its right to a 

hearing;

(5) that the failure of the Respondent to file an Answer (as defined in Rule 505) with the 

Market Regulation Staff within twenty (20) days of service of the Notice shall be deemed 

an admission of all of the acts, practices or conduct alleged in the Notice; and

(6) that the failure of the Respondent to expressly deny a particular charge contained in the 

Notice shall be deemed an admission of such acts, practices or conduct.

(b) A Respondent shall have the right to be represented by legal counsel or any other representative 

of its choosing in all succeeding stages of the disciplinary process, except by any member of the Board, 

Review Panel or Hearing Panel, any employee of IGDL or any person substantially related to the 

underlying investigation, such as a material witness or Respondent.

Rule 505 Answer; Request for Hearing; Failure to Answer or Deny Charges

(a) The Respondent shall serve on the Compliance Function a written answer (an “Answer”) to the 

Notice and a written request for a hearing on the charges within thirty (30) days of the date of service of 

the Notice. The Answer must include a statement that the Respondent admits, denies, or does not have 
60

and is unable to obtain sufficient information to deny each allegation. A statement of lack of sufficient 

information shall have the effect of a denial of the allegation.

(b) The Respondent’s failure to file an Answer within such thirty (30) day period shall be deemed an 

admission of all allegations contained in the Notice.

(c) The Respondent’s failure to expressly deny a particular charge contained in the Notice shall be 

deemed an admission of such acts, practices or conduct.

(d) The Respondent’s failure to request a hearing within such thirty (30) day period, absent good 

cause shown, shall be deemed a waiver of Respondent’s right to a hearing.

Rule 506 Selection of Hearing Panel

(a) Formal hearings on any Notice shall be conducted by the Hearing Panel selected by the Board. 

The Hearing Panel shall include at least two Participants and at least two non-Participants. In the case 

where any Respondent is a Clearing Firm, at least one member of the Hearing Panel shall be a Clearing 

Firm. The Board shall also select, as chairman of the Hearing Panel (“Hearing Panel Chairman”), a 

person who would not be disqualified from serving as a “Public Director” as defined in Commission 

Regulations. The Hearing Panel Chairman, in his or her sole discretion, shall set a date for the hearing 

(the “Hearing Date”). The Hearing Panel may not include any members of the Market Regulation Staff, 

any person involved in adjudicating any other stage of the same Proceeding, or any person with a history 

of disciplinary offenses that would be disqualifying under CFTC Regulation § 1.63(c). The Hearing Panel 

shall include at least one member that is not a member of IGDL whenever the Hearing Panel is: (i) acting 

with respect to a disciplinary action in which the Respondent is a member of the Board, the Review Panel 

or the Hearing Panel; or (ii) when the suspected violation involves manipulation (or attempted 

manipulation) of the price of a Contract or conduct which directly results in financial harm to a 

non-member of IGDL. The Hearing Panel shall include sufficient different membership interests so as to 

ensure fairness and to prevent special treatment or preference for any person.

(b) The Hearing Panel Chairman shall notify the Market Regulation Staff and the Respondent of the 

Hearing Date and the names of the members of the Hearing Panel at least fifteen (15) days prior to the 

Hearing Date.

(c) No member of the Hearing Panel shall hear a case in which that member has a direct financial, 

personal or other interest in the matter under consideration.

Rule 507 Challenge to Members of the Hearing Panel

Within ten (10) days after service on the Respondent of notice of the Hearing Date and names of the 

members of the Hearing Panel, the Respondent may challenge, in writing, the inclusion of any member of 

the Hearing Panel for cause, including without limitation, if the member has a direct financial, personal or 

other interest in the matter under consideration. The merits of such challenge shall be finally decided by 

the Regulatory Oversight Committee. If said written challenge is not received within such ten (10) day 

period, absent good cause shown, any such right to challenge is deemed waived.

Rule 508 Hearing on Sanctions in the Event of Failure to Deny Charges; Failure to Request 

Hearing Deemed Acceptance of Sanctions

In the event the Respondent fails to file an Answer or admits or fails to deny the charge of a Violation 

contained in the Notice, the Hearing Panel shall find the Respondent guilty of each such Violation and 

may impose a sanction for each such Violation subject to the limitations set forth in Rule 511(b)(7). The 

Hearing Panel shall promptly notify the Respondent of any such sanction and of the Respondent’s right to 

a hearing on the sanction within the period of time which shall be stated in the notice, after the imposition 
61

of such sanction. Failure to request a hearing on the sanction in a timely manner, absent good cause 

shown, shall be deemed to be acceptance of the sanction.

Rule 509 Settlement Prior to Commencement of Hearing

(a) Prior to the commencement of the hearing, the Hearing Panel may accept a written offer of 

settlement from the Respondent, whereby the Respondent, without either admitting or denying any 

Violations, may agree to:

(1) a cease and desist order;

(2) a fine for each Violation plus the monetary value of any benefit received as a result of the 

Violation (provided that in no case shall any fine exceed $100,000 per Violation);

(3) restitution of any counterparty harm; and/or

(4) revocation or suspension of Trading Privileges or Customer or Clearing Firm status of the 

Respondent.

(b) If the Hearing Panel accepts an offer of settlement, it must issue a written decision specifying 

each Violation it has reason to believe was committed, including the basis for the Hearing Panel’s 

conclusions. The sanctions must include full counterparty restitution where counterparty harm is 

demonstrated, except where the amount of restitution or to whom it should be provided cannot be 

reasonably determined. If an offer of settlement is accepted without the support of the Market Regulation 

Staff, the decision must adequately support the Hearing Panel’s acceptance of the settlement. Where 

applicable, the decision must include a statement that the Respondent has accepted the sanctions 

imposed without either admitting or denying any Violations. Any sanctions imposed pursuant to an offer 

of settlement must take into account the Respondent’s disciplinary history.

(c) The Respondent may withdraw an offer of settlement at any time before final acceptance by the 

Hearing Panel. If an offer is withdrawn after submission, or is rejected by the Hearing Panel, the 

Respondent may not be deemed to have made any admissions by reason of the offer of settlement and 

may not be otherwise prejudiced by having submitted the offer of settlement.

Rule 510 Hearing Procedures

(a) In every instance where a Respondent has requested a hearing on a charge that is denied, or on 

a sanction set by the Hearing Panel pursuant to Rule 508, the Respondent will have the opportunity for a 

hearing in accordance with the procedures of this Rule.

(b) The Hearing Panel shall determine the procedures to be followed in any hearing before it, except 

that the following shall apply in every case:

(1) The hearing must be fair and must be promptly convened after reasonable notice to the 

Respondent.

(2) The prosecution shall be conducted by the Market Regulation Staff.

(3) The Respondent shall be allowed to appear personally at the hearing, and to be 

represented by legal counsel or any other representative of its choosing and, either 

personally or through such representative, to present witnesses and documentary 

evidence and to cross-examine witnesses.

(4) The Market Regulation Staff and the Respondent shall deliver to each other a statement 

listing the witnesses expected to be called and the documents expected to be introduced 
62

into evidence, together with copies of such documents, by ten (10) days’ prior notice to 

the hearing or as the Hearing Panel may reasonably specify. Unless the Hearing Panel, 

in its discretion, waives compliance with this requirement, no witness may testify and no 

documentary evidence may be introduced into evidence unless listed in and, in the case 

of documents, furnished with such statement. On written request, the Market Regulation 

Staff shall provide the Respondent with access to all books, documents or other tangible 

evidence in the possession or under the control of IGDL which are to be relied upon by 

the Market Regulation Staff or which are relevant to the charges; provided, however, that 

protected attorney work product, attorney-client communications and investigative work 

product, including the investigation report, are neither discoverable by a Respondent nor 

subject to review by a Respondent as part of the investigation file.

(5) IGDL shall require that persons within its jurisdiction who are called as witnesses 

participate in the hearing and produce evidence, and will make reasonable efforts to 

secure the presence of all other persons called as witnesses whose testimony would be 

relevant. Failure by a Facility Subject Person to so participate and produce evidence 

when requested by IGDL shall be a Violation.

(6) No formal rules of evidence shall apply, and the Hearing Panel shall be free to accept or 

reject any and all evidence it considers proper, but the hearing may not be so informal as 

to deny a fair hearing.

(7) Neither the Market Regulation Staff, the Respondent, any witnesses testifying before the 

Hearing Panel nor any other person within the Facility’s jurisdiction shall engage in 

conduct that may impede the progress of a hearing or the fair and just resolution of the 

subject matter thereof, and any such conduct may itself constitute a Violation.

(8) Ex parte contacts by any of the parties with members of the Hearing Panel shall not be 

permitted.

(9) A substantially verbatim record capable of being accurately transcribed shall be made of 

the Proceeding, provided, however, that such record need not be transcribed, unless the 

transcript is requested by the Respondent or an applicable regulator, or unless the 

decision is appealed to the Commission or reviewed by the Commission on its own 

motion. In all other instances, a summary record of the hearing is permitted.

(10) The cost of transcribing the record of the hearing must be borne by a Respondent who 

requests the transcript, or whose application for Commission review of the disciplinary 

action has been granted. In all other instances, the cost of transcribing the record will be 

borne by IGDL.

(11) The Notice, the Answer, any stenographic transcript of the hearing, the documentary 

evidence and any other material presented to the Hearing Panel by either party with 

notice to the other shall constitute the record of the hearing (the “Hearing Record”).

(12) The burden of proof shall be on the prosecution to prove a Violation by a preponderance 

of the evidence. A finding of a Violation shall be made by majority vote based on the 

Hearing Panel’s decision as to the weight of the evidence contained in the Hearing 

Record.

(13) All sanctions imposed by the Hearing Panel must be commensurate with the Violations 

committed and must be clearly sufficient to deter additional similar Violations by the 

Respondent and similar Violations by other Facility Subject Persons. All sanctions must 

take into account the Respondent’s disciplinary history. In the event of demonstrated 

counterparty harm, any sanctions must include full counterparty restitution, except where 
63

the amount of restitution or to whom it should be provided cannot be reasonably 

determined.

Rule 511 Written Decision of Hearing Panel

(a) Promptly following a hearing conducted in accordance with Chapter 5 of the Rules, the Hearing 

Panel shall render a written decision based upon the weight of evidence in the Hearing Record and must 

provide a copy to the Respondent within thirty (30) days of such decision.

(b) The written decision shall include:

(1) the name of the Respondent;

(2) a summary of the charges alleged in the Notice;

(3) a summary of the Answer;

(4) a summary of the evidence produced at the hearing or, where appropriate, incorporation 

by reference of the investigation report;

(5) a statement of the findings and conclusions of the Hearing Panel with respect to each 

charge, and a complete explanation of the evidentiary and other basis for such findings 

and conclusions with respect to each charge, or in the event of a settlement, a statement 

specifying the alleged Violations;

(6) an indication of each specific Rule that the Respondent was found to have violated and 

whether the Violation resulted in any financial harm to Customers;

(7) an order stating any sanctions imposed, including the basis for the sanctions, any terms 

of the sanctions, the date the determination to impose sanctions was made and the 

effective date of such sanctions; the sanctions that may be imposed on the Respondent 

shall be one or more of the following:

(i) a cease and desist order;

(ii) a fine for each Violation plus the monetary value of any benefit received as a 

result of the Violation (provided that in no case shall any fine exceed $100,000 

per Violation);

(iii) restitution of counterparty harm, except where the amount of restitution or to 

whom it should be provided cannot be reasonably determined; and/or

(iv) the issuance of a suspension or revocation of Trading Privileges or Customer or 

Clearing Firm status of the Respondent; and

(8) a statement informing the respondent that the imposition of sanctions may be appealed

to the Commission pursuant to Part 9 of the Commission Regulations.

(c) The Hearing Panel shall take into consideration the Respondent’s disciplinary history prior to 

imposing any disciplinary sanctions.

(d) IGDL shall also provide the written decision to the NFA through BASIC, or deliver the written 

decision to the NFA to be input into BASIC.
64

(e) If IGDL suspends or revokes the Trading Privileges or Customer or Clearing Firm status of the 

Respondent, it must publicly publish the information contained in the written notice pursuant to 

Rule 511(b).

Rule 512 Liability for Expenses

Any Respondent that, after notice and opportunity for hearing, has been found to have committed a 

Violation may, in the discretion of the Hearing Panel appointed in the matter, be required to pay to IGDL 

an amount equal to any and all reasonable and documented out-of-pocket expenses incurred by IGDL in 

connection with the prosecution of such Violations, in addition to any fine or other monetary sanction 

which may be imposed upon such Respondent by virtue of the Violations found by the Hearing Panel.

Rule 513 Effective Date of Sanctions

(a) If a Respondent submits an offer of a settlement to the Hearing Panel, any sanction included as a 

part of such settlement shall become final and effective on the date that the Hearing Panel approves such 

settlement, or on such other date as is specified in the decision.

(b) Subject to Rule 513(c) and (d), any decision (including any sanctions) by a Hearing Panel 

pursuant to this Chapter 5 or the Participation Committee pursuant to Rule 205 shall be the final decision 

of IGDL and shall become effective fifteen (15) days, or such longer time as the Hearing Panel or 

Participation Committee may specify, after a copy of the written decision of the Hearing Panel or 

Participation Committee has been served on the Respondent, applicant, Participant or Customer as 

applicable.

(c) In any case where a Respondent, applicant, Participant or Customer has consented to the action 

taken and to the timing of its effectiveness, the Hearing Panel or Participation Committee may cause the 

decision involving any disciplinary action (including any sanctions) to become effective prior to the fifteen 

(15) day period.

(d) Any decision (including any sanctions) by a Hearing Panel or the Participation Committee may 

become effective prior to the time set forth in Rule 513(b) if:

(1) IGDL reasonably believes, and so states in its written decision, that immediate action is 

necessary pursuant to Rule 514;

(2) IGDL determines and so states in its written decision, that the actions of a SEF Subject 

Person have impeded the progress of a disciplinary hearing; or

(3) IGDL determines a SEF Subject Person has violated Rules relating to timely submission 

of accurate records required for clearing or verifying each day’s transactions or other 

similar activities.

(e) If a decision is to become effective earlier than the time set forth in Rule 513(b) pursuant to 

Rule 513(c) or Rule 513(d), IGDL shall notify the Respondent, applicant, Participant or Customer in 

writing stating the reasons for the determination.

(f) Any fine or other monetary sanction imposed by a Hearing Panel shall be due and payable on the 

effective date of the decision imposing such fine or sanction, or on such later date as the Hearing Panel 

may specify.

Rule 514 Summary Suspension

(a) A Facility Subject Person (as identified by Market Regulation Staff in an investigation or by a 

Trading Privilege Holder acting as an Intermediary for such Facility Subject Person) may be summarily 
65

and immediately suspended from trading on the Facility, upon a written determination based on a 

reasonable belief, by the Chairman of the Regulatory Oversight Committee that such immediate action is 

necessary to protect the best interest of the market place.

(b) The Facility Subject Person against whom such summary action is taken shall be served with a 

notice of the action either before the action is taken or at the earliest possible opportunity thereafter. The 

notice shall state the action taken, the reasons for the action, the effective date and time, and the duration 

of the action.

(c) The Facility Subject Person may as soon as practicable, upon written request, have a hearing 

before the Hearing Panel pursuant to the procedures of Rule 510.

(d) Promptly following the hearing, the Hearing Panel shall render a written decision based upon the 

weight of the evidence in the record and shall provide a copy to the Facility Subject Person. The decision 

shall include a description of the summary action taken, the reasons for the summary action, a summary 

of the evidence produced at the hearing, a statement of findings and conclusions, a determination that the 

summary action should be affirmed, modified or reversed, a declaration of any action to be taken 

pursuant to the determination, and the effective date and duration of the action.

Rule 515 Extension of Time Limits

Any time limit provided for in Rule 504, Rule 505, Rule 506, Rule 507, Rule 508, or Rule 510 may be 

extended by mutual consent of the Respondent and the Market Regulation Staff, or by the Hearing Panel 

Chairman.

Rule 516 Summary Fines

(a) Notwithstanding any other provision of this Chapter 5, the Compliance Function or its designee 

shall have the authority to impose summary fines on Participants and Customers without the need for any 

formal disciplinary procedures with respect to Violations of any Rule listed in Rule 516(e). Pursuant to 

Rule 202(a)(1)(ii), a Participant that is an Intermediary may be held responsible for a Violation by its 

Customer. Investigations of possible Violations of such a Rule shall be conducted in accordance with 

Rule 502, but otherwise actions taken pursuant to this Rule 516 shall be made in accordance with the 

procedures set forth herein rather than the procedures set forth in the remainder of this Chapter 5. The 

authority to impose a summary fine under this Rule 516 does not prevent the Compliance Function from 

submitting a Violation of any rule listed in Rule 516(e) to the Review Panel in accordance with the formal 

disciplinary procedures of this Chapter 5.

(b) The Compliance Function or its designee shall give written notice to each Participant and 

Customer subject to any summary fine imposed pursuant to this Rule 516. The written notice (“Fine 

Notice”) shall set forth: (i) the provision of the Rules allegedly Violated; (ii) the act or omission 

constituting each such Violation; (iii) the fine imposed for each Violation; and (iv) the date by which such 

fine becomes final and must be paid or contested as provided below, which date shall be not less than 

30 days after the date the Fine Notice was provided to the Participant or Customer.

(c) Any Participant or Customer against whom a summary fine is imposed pursuant to this Rule 516

may contest the imposition of such fine by serving on the Compliance Function a written answer to the 

Fine Notice. Such answer (“Notice of Contest”) must: (i) state that the Participant or Customer contests 

the imposition of the fine; (ii) acknowledges that the alleged Violation will be referred to the Review Panel; 

and (iii) be submitted to the Compliance Function on or before the date specified in the Fine Notice. 

Upon submission of a Notice of Contest the matter shall become subject to review by the Review Panel in 

accordance with the formal disciplinary procedures set forth in the remainder of this Chapter 5 and shall 

no longer be subject to this Rule 516.
66

(d) For purposes of imposing fines pursuant to this Rule 516, the Compliance Function shall review 

all the facts and circumstances prior to determining whether a Violation occurred and may aggregate 

individual Violations and treat such Violations as a single offense.

(e) The Compliance Function shall set the amount of any fine imposed pursuant to this Rule 516, 

with the maximum aggregate fine for Violations of the same Rule, or subsection thererof, imposed by the 

Compliance Function not to exceed $7,000 on an annual basis. If, in any case, the Compliance Function 

or another member of the Market Regulation Staff, designated for this purpose by the Compliance 

Function, concludes that there is a reasonable basis for finding an additional Violation, he or she shall 

present an investigation report concerning the matter to the Review Panel in accordance with Rule 502, 

which shall proceed in accordance with Rule 503. The following schedule lists the recommended actions 

that the Compliance Function may impose:

Rule 

Violation

Action Taken Per each Violation in a Rolling 12-month period

First 

Violation

Second 

Violation

Third 

Violation

Fourth Violation

Rule 204(i) Warning 

Letter

$2,000 $5,000 Referral to Review Panel for formal 

disciplinary procedures.
67

CHAPTER 6

CONTRACTS TO BE TRADED

Rule 601 Listing Procedures

Any Trading Privilege Holder may propose to IGDL the listing of a Swap on the Facility by submitting a 

listing application to IGDL. The Chief Executive Officer shall have authority subject to complying with 

Rule 602 and to objectively justifiable commercial criteria, to submit the contract to the Commission, 

either with a request for prior approval, or with a self-certification.

Rule 602 Swaps Not Readily Susceptible to Manipulation

Before the Chief Executive Officer submits a Swap to the Commission for prior approval or with a 

self-certification, the Chief Compliance Officer shall determine that the Swap is not readily susceptible to 

manipulation, and shall submit to the Commission the following information required by Appendix C to 

Part 38 of Commission Regulations to show that the Swap complies with Core Principle 3:

(a) For cash-settled Swaps, documentation demonstrating that the settlement price index is a reliable 

indicator of market values and conditions, is highly regarded by industry/market agents, and is publicly 

available on a timely basis.

(b) Where an independent, private-sector third party calculates the referenced price index, 

verification that the third party utilises business practices that minimise the opportunity or incentive to 

manipulate the cash settlement prices included in the index.

(c) Where IGDL generates the cash settlement prices included in the index, information 

demonstrating that the calculation procedures safeguard against potential attempts to artificially influence 

the price, and a description of how the calculation procedures eliminate or reduce the impact of potentially 

unrepresentative data.

(d) Appropriate speculative limits to prevent manipulation.

(e) Procedures for intraday market restrictions that pause or halt trading in the event of extraordinary 

price moves that may result in distorted prices.
68

CHAPTER 7

GOVERNING LAW, JURISDICTION AND DISPUTE RESOLUTION

Rule 701 Choice of Law

The laws of England and Wales, without regard to its conflict of laws principles, will govern this Rulebook 

and all disputes arising out of or related to IGDL, the Facility or any transaction on the Facility.

Rule 702 Disputes Among Trading Privilege Holders, Authorised Traders, Authorised Trading 

Firms and Customers

All disputes between and among Facility Subject Persons that arise out of or relate to IGDL or the Facility 

or any transaction that was made or attempted to be made on the Facility shall be resolved exclusively in 

the courts of England and Wales, save for in the following circumstance:

(1) if all parties to the dispute are members or associates of the NFA, the dispute will be 

resolved in NFA Member Arbitration; or

(2) if all parties separately agree to another forum, the dispute will be resolved in the other 

forum.

Rule 703 Disputes with IGDL

(a) Subject to Rule 102, all disputes between and among IGDL on the one hand, and Facility Subject 

Persons on the other hand, that arise out of or relate to the Facility, or any transaction that was made or 

attempted to be made on the Facility, shall be resolved exclusively in the courts of England and Wales. 

Suit on any such dispute must be brought within one year from the time the cause of action has accrued.

(b) Any current or former Facility Subject Person who does not substantially prevail in a lawsuit or 

any other type of legal proceeding instituted in a court of law or otherwise against IGDL or any of its 

officers, directors, committee members, volunteers, employees or agents, shall pay to IGDL any and all 

reasonable expenses and disbursements, including reasonable attorneys’ fees, incurred by IGDL to 

defend such lawsuit or proceeding.
69

CHAPTER 8

CONTRACT SPECIFICATIONS

Rule 801 Interest Rate Swaps Products Descriptions

Trading Hours

Unless otherwise indicated in a Swap’s specifications, the trading hours for all Swaps governed by this 

Rule 801 are as follows:

o Order Book:

 1:30 a.m. – 5:30 p.m. Eastern Time, Monday to Friday (i-Swap)

 5:30 p.m. – 1:30 a.m. Eastern Time, Monday to Friday (GTN)

 3:00 p.m. Sunday – 1:30 a.m. Monday, Eastern Time (GTN)

o Voice RFQ: 24 Hours, Monday to Friday.

o All Pre-Arranged Crosses: 24 Hours, Monday to Friday.

Products — Rule 801:

(1) Fixed for Floating IRS

(2) Basis Swaps

(3) Forward Rate Agreements (FRA)

(4) Overnight Index Swaps (OIS)

(5) Interest Rate Options

(a) Swap Options

(b) Inflation Swaps

(c) Inflation Rate Options

(d) Exotic Options and Swaps
70

Product Specifications

Rule 801(1) — Fixed for Floating IRS

A Fixed for Floating IRS is an Interest Rate Swap for which settlement is in the form of periodic fixed 

interest payments and a stream of periodic floating interest payments based on an interest rate over a 

term to maturity. The interest rate payments are exchanged for a specified period based on a notional 

amount.

Currencies

USD

EUR

GBP

Specifications

Trading Conventions

o Buyer (Payer) pays fixed interest rate and receives floating interest rate.

o Seller (Receiver) receives fixed interest rate and pays floating interest rate.

Upfront Payment Dates:

o USD – T+1 through maturity

o EUR – T+1 through maturity

o GBP – T+1 through maturity

Settlement Convention:

o USD – T+2

o EUR – T+2

o GBP – T+2

Swap Leg Conventions

o The terms of Fixed versus Floating Interest Rate Swaps are based on a number of 

combinations of the criteria below.

 Fixed Leg

• Payment Frequency

o Monthly, Quarterly, Semi-Annually, or Annually

• Day Count Convention

o 30/360, Actual/360, Actual/365.FIXED, Actual/Actual.ISDA, 

30E/360, 30E/360.ISDA, Actual/Actual.ICMA

• Holiday Calendar

o Applied in accordance for the country currency denoted for the 

instrument

• Business Day Convention

o Modified following with adjustment to period end dates. 

Business days in this convention must be valid business days for 

the countries denoted by the currency (EUTA, GBLO, USNY). If 

not, it will be the next day that is a business day on both 

calendars.

• Fixed Rate

o The traded interest rate yield or basis points on Trade Date

 Floating Leg

• Reset Frequency

o Monthly, Quarterly, Semi-Annual

• Day Count Convention

o 30/360, Actual/360, Actual/365.FIXED, Actual/Actual.ISDA, 

30E/360, 30E/360.ISDA, Actual/Actual.ICMA

• Holiday Calendar

o Applied in accordance for the country currency denoted for the 

instrument
71

• Business Day Convention

o Modified Following with adjustment to period end dates. 

Business days in this convention must be valid business days for 

the countries denoted by the currency (EUTA, GBLO, USNY). If 

not, it will be the next day that is a business day on both 

calendars.

• Fixed Rate

o The traded interest rate yield or basis points on Trade Date

• Interest Rate Benchmark

o EUR-EURIBOR-Reuters, EUR-EURIBOR-Telerate(incoming), 

GBP-LIBOR-BBA, USD-LIBOR-BBA.

o Leg Computation Convention: none, flat, straight or spread exclusive.

Trade Date

o The date on which the parties enter into the Swap transaction.

Effective Date

o The first date from which fixed and floating interest amounts accrue. It is also referred to as 

the Start Date or the Value Date. The Effective Date of the Swap must be a business day 

subject to the appropriate Business Day Convention.

Trade Start Type

o Spot Starting

 A swap whose Effective Date is 2 business days from the Trade Date (T+2).

o Forward Starting

 A swap whose Effective Date is anything after the Effective Date for a Spot 

Starting swap.

o Same Day Starting

 A swap whose Effective Date is the same as the Trade Date (T+0).

Maturity Date

o The final date until which Fixed and Floating amounts accrue. The Maturity Date may also be 

referred to as the Termination Date or End Date.

Tenor

o The duration of time from the Effective Date to the Maturity Date. Tenors of any duration 

greater than 0 years to 50 years.

o Listed Tenors, also known as On-the-Run, are whole calendar year Spot Starting Contracts 

with a Tenor of 1 through 51 years.

o Other Tenors, also known as Off-the-Run, means any partial year Tenor (Months, Weeks, 

Days).

Roll Day Convention

o The date used for determining all fixed and floating Reset Dates. Roll Days define the 

beginning and end of Fixed and Floating interest accrual periods.

o For On-the-Run Contracts, the Roll Day is the same date of the month as the Effective Date. 

For Off-the-Run Contracts, it can be any date of the month, subject to the provisions of the 

Business Day Convention. Roll Day marks the start of a new interest accrual period, and is 

the date on which a Reset Rate takes effect.

Floating Reset Dates

o Dates utilized to determine the Floating Rate amounts for each interest accrual period during 

the Tenor of the contract. Except in the case of a Stub Period, the Reset Date is aligned with 

the floating rate frequency as determined.
72

First Period Fixing Date

o For Spot Starting swaps, the Interest Rate for the first interest period is fixed on the Trade 

Date, for both Floating and Fixed Rates.

o For Forward Starting swaps, the Fixed Rate for the first interest period is fixed on the Trade 

Date, and the Floating Rate for the first interest period is fixed 2 business days prior to the 

first floating payment date, taking into account agreed non-working days.

Stub Period Rate

o For swaps with partial year Tenors, an interest period that is shorter than the standard 

underlying Floating index interest periods may occur between the Effective Date and the first 

or last Roll Date (knows as a Stub Period). In these cases, the Interest Rate for such Stub 

Period is determined using linear interpolation based on the two index rates that surround the 

Stub Period this can be applied either at the start or end of that period: Front or Back.

Trade Types

o The Platform may support the following trade types:

 Outrights

• An Outright swap is where one party is the payer of the fixed rate and 

receiver of the floating rate and the other party is the receiver of the fixed 

fate and payer of the floating rate.

 Switches or Spreads

• Is the simultaneous purchase and sale of two different Tenors of the 

yield curve (e.g. 2 year by 10 year).

 Butterflies

• Butterflies are a combination of two spreads/switches (e.g. 2 year by 

5 year by 10 year).

Contract Size

o Minimum notional size is dependent on currency and tenor.

Minimum Price Fluctuation

o Outrights

 The interest rate yield is quoted in increments of a minimum of .000025 (1/40th of 

a basis point).

o Spreads and Butterflies will be quoted in basis points dependent in multiples of the 

increments of the underlying Outrights.

Final Settlement Price

o Multiple payments take place during the term of the swap. Settlement price used for the 

periodic exchange of fixed and floating payments is based on the following factors:

 Fixed Leg

• Payment amount on the fixed leg is based on the traded price and 

notional amounts of the swap on Trade Date. Payment timing on the 

fixed leg is based on the Payment Frequency, Day Count Convention, 

Business Day Convention, and Roll Day.

 Floating Leg

• Payment on the floating leg is based on the Interest Rate and notional 

amounts of the swap. Payments on the floating leg are based on the 

Payment Frequency, Day Count Convention, Business Day Convention, 

Roll Day Convention, Spread (if any), Floating Rate Day Count Fraction 

and Floating Reset Dates.

Additional Payments/Fees

o None.
73

Clearing

o Contracts are eligible to be cleared at CME, LCH.Clearnet and JSCC.
74

Rule 801(2) — Basis Swaps

A Basis Swap is an Interest Rate Swap for which settlement is in the form of periodic floating interest 

payments and periodic floating interest payments based on interest rate benchmarks over a term to 

maturity. The interest rate payments are exchanged for a specified period based on a notional amount.

Currencies

USD

EUR

GBP

Specifications

Trading Conventions

o Buyer (Payer) pays floating interest rate plus/minus a spread and receives floating interest 

rate.

o Seller (Receiver) receives floating interest rate plus/minus a spread and pays floating interest 

rate.

Supported Basis Combinations

o 1M EURIBOR vs 3M EURIBOR

o 1M EURIBOR vs 6M EURIBOR

o 3M EURIBOR vs 6M EURIBOR

o 1M GBP-LIBOR vs 3M GBP-LIBOR

o 1M GBP-LIBOR vs 6M GBP-LIBOR

o 3M GBP-LIBOR vs 6M GBP-LIBOR

o 1M USD-LIBOR vs Federal Funds H.15

o 3M USD-LIBOR vs Federal Funds H.15

o 6M USD-LIBOR vs Federal Funds H.15

o 1M USD-LIBOR vs 3M USD-LIBOR

o 1M USD-LIBOR vs 6M USD-LIBOR

o 3M USD-LIBOR vs 6M USD-LIBOR

Upfront Payment Dates:

o USD – T+1 through maturity

o EUR – T+1 through maturity

o GBP – T+1 through maturity

Settlement Convention:

o USD – T+1

o EUR – T+1

o GBP – T+1

Swap Leg Conventions

o The terms of Floating vs. Floating Interest Rate Swaps are based on a number of 

combinations of the criteria below.

 Floating Leg 1

• Payment Frequency

o Monthly, Quarterly, Semi-Annually, or Annually

• Day Count Convention

o 30/360, Actual/360, Actual/365.FIXED, Actual/Actual.ISDA, 

30E/360, 30E/360.ISDA, Actual/Actual.ICMA

• Holiday Calendar

o Applied in accordance for the country currency denoted for the 

instrument

• Business Day Convention

o Modified Following with adjustment to period end dates. 

Business days in this convention must be valid business days on 
75

both the calendars (EUTA, GBLO, USNY). If not, it will be the 

next day that is a business day on both calendars.

• Floating Rate

o The floating interest rate yield or basis points on Trade Date

 Floating Leg 2

• Reset Frequency

o Monthly, Quarterly, Semi-Annual or Annually

• Day Count Convention

o 30/360, Actual/360, Actual/365.FIXED, Actual/Actual.ISDA, 

30E/360, 30E/360.ISDA, Actual/Actual.ICMA

• Holiday Calendar

o Applied in accordance for the country currency denoted for the 

instrument

• Business Day Convention

o Modified Following with adjustment to period end dates. 

Business days in this convention must be valid business days on 

both calendars (EUTA, GBLO, USNY). If not, it will be the next 

day that is a business day on calendars.

• Interest Rate Benchmark

o EUR-EURIBOR-Reuters, EUR-EURIBOR-Telerate (incoming), 

GBP-LIBOR-BBA, USD-LIBOR-BBA.

Trade Date

o The date on which the parties enter into the Swap transaction.

Effective Date

o The first date from which floating interest amounts accrue. It is also referred to as the Start 

Date or the Value Date. The Effective Date of the Swap must be a business day subject to 

the appropriate Business Day Convention.

Trade Start Type

o Spot Starting

 A swap whose Effective Date is 2 business days from the Trade Date (T+2).

o Forward Starting

 A swap whose Effective Date is anything after the Effective Date for a Spot 

Starting swap.

o Same Day Starting

 A swap whose Effective Date is the same as the Trade Date (T+0).

Maturity Date

o The final date until which Floating amounts accrue. The Maturity Date may also be referred 

to as the Termination Date or End Date.

Tenor

o The duration of time from the Effective Date to the Maturity Date. The Exchange will support 

Tenors of any duration greater than 0 years to 50 years.

o Listed Tenors, also referred to as On-the-Run, means whole year Spot Starting or Same Day 

Starting Instruments with a Tenor of 1 through 15, 20, 25, 30, 35, 40,45 and 50 years.

o Other Tenors means any whole year Tenors other than the Listed Tenors and any partial 

year Tenor.

Roll Day Convention

o The date used for determining all fixed and floating Reset Dates. Roll Days define the 

beginning and end of Floating interest accrual periods.

o For On-the-Run Instruments, the Roll Day is the same date of the month as the Effective 

Date. For Off-the-Run Instruments, it can be any date of the month, subject to the provisions 

of the Business Day Convention. Roll Day marks the start of a new interest accrual period, 

and is the date on which a Reset Rate takes effect.
76

 Note: Subject to good business days – as with all instruments, will never roll 

forward to the following month.

Floating Reset Dates

o Dates utilized to determine the Floating Rate amounts for each interest accrual period during 

the Tenor of the Instrument. Except in the case of a Stub Period, the Reset Date is 2 

business days (USD, EUR) or zero business days (GBP) prior to the Roll Date for that 

interest accrual period.

First Period Fixing Date

o For Spot Starting and Same Day Starting swaps, the Interest Rate for the first interest period 

is fixed on the Trade Date, for both Floating Rates.

o For Forward Starting swaps, the Floating Rate for the first interest period is fixed on the 

Trade Date, and the Floating Rate for the first interest period is fixed 2 business days prior to 

the Effective Date.

Stub Period Rate

o For swaps with partial year Tenors, an interest period that is shorter than the standard 

underlying Floating index interest periods may occur between the Effective Date and the first 

or last Roll Date (knows as a Stub Period). In these cases, the Interest Rate for such Stub 

Period is determined using linear interpolation based on the two index rates that surround the 

Stub Period this can be applied either at the start or end of that period: Front or Back.

Trade Types

o The Platform may support the following trade types:

 Outrights

• An Outright swap is where one party is the payer of the floating rate 1 

plus/minus a spread and receiver of the floating rate 2 and the other 

party is the receiver of the floating rate 1 plus/minus a spread and payer 

of the floating rate 2.

 Switches

• Switches are the simultaneous purchase and sale of two different Tenors 

of the yield curve (e.g. 2 year by 10 year).

 Butterflies

• Butterflies are the simultaneous purchase(s) and sale(s) of three different 

tenors of the yield curve (e.g. 2 year by 5 year by 10 year).

Instrument Minimum and Incremental Size

o Minimum notional size is dependent on currency and tenor.

o Block Trades

 Minimum notional size as stated by the Commission and increments dependent 

on currency and tenor.

Quoting Convention

o Outrights are quoted in interest rate yield in a minimum 1/10th of a basis point increments.

o Spreads and Butterflies are quoted in interest rate yield differential in minimum 1/10th basis 

point increments.

 Spot Starting

• Close of business on Trade Date.

 Forward Starting

• Close of business three business days prior to the Effective Date of the 

swap.

 Block Trades must occur outside the Order Book and in a quantity that meets or 

exceeds Appropriate Minimum Block Sizes set by the Commission.

Final Settlement Price

o Multiple payments take place during the term of the swap. Settlement price is based on the 

following factors, which must be specified by the parties:
77

 Interest rate, interest rate benchmark, notional amounts of the swap, Payment 

Frequency, Day Count Convention, Business Day Convention, Roll Day 

Convention, Spread (if any), Floating Rate Day Count Fraction and Floating 

Reset Dates.

Additional Payments/Fees

o None.

Clearing

o Contracts are eligible to be cleared at CME, LCH.Clearnet and JSCC.
78

Rule 801(3) — Forward Rate Agreement (FRA)

A Forward Rate Agreement is an Interest Rate Swap for which settlement is in the form of one fixed 

interest payment and one floating interest payment based on an interest rate benchmark to be paid or 

received on an obligation beginning at a future start date. The interest rate payments are exchanged 

based on a notional amount.

Currencies

USD

EUR

GBP

Specifications

Trading Conventions

o Buyer (Payer) pays fixed interest rate and receives floating interest rate.

o Seller (Receiver) receives fixed interest rate and pays floating interest rate.

Upfront Payment Dates:

o USD – T+1 through maturity

o EUR – T+1 through maturity

o GBP – T+1 through maturity

Settlement Convention:

o USD – T+1

o EUR – T+1

o GBP – T+1

Swap Leg Conventions

o The terms of FRAs are based on a number of combinations of the criteria below.

 Fixed Leg

• Payment Frequency

o Once

• Day Count Convention

o 30/360, Actual/360, Actual/365.FIXED, Actual/Actual.ISDA, 

30E/360, 30E/360.ISDA, Actual/Actual.ICMA

• Holiday Calendar

o Applied in accordance with the country relating to the currency of 

the instrument

• Business Day Convention

o Modified Following with adjustment to period end dates. 

Business days in this convention must be valid business days on 

both the holiday calendars of that country (EUTA, GBLO, 

USNY). If not, it will be the next day that is a business day on 

both calendars.

• Fixed Rate

o The traded interest rate yield or basis points on Trade Date

 Floating Leg

• Reset Frequency

o Once

• Day Count Convention

o 30/360, Actual/360, Actual/365.FIXED, Actual/Actual.ISDA, 

30E/360, 30E/360.ISDA, Actual/Actual.ICMA

• Holiday Calendar

o Applied in accordance with the country relating to the currency of 

the instrument

• Business Day Convention

o Modified Following with adjustment to period end dates. 

Business days in this convention must be valid business days on 

both the calendars for each country (EUTA, GBLO, USNY). If 
79

not, it will be the next day that is a business day on both 

respective country holiday calendars.

• Interest Rate Benchmark

o EUR-EURIBOR-Reuters, EUR-EURIBOR-Telerate (incoming), 

GBP-LIBOR-BBA, USD-LIBOR-BBA

Trade Date

o The date on which the parties enter into the Swap transaction.

Effective Date

o The first date from which fixed and floating interest amounts accrue. It is also referred to as 

the Start Date or the Value Date. The Effective Date of the Swap must be a business day

subject to the appropriate Business Day Convention.

Maturity Date

o The final date until which Fixed and Floating amounts accrue. The Maturity Date may also be 

referred to as the Termination Date or End Date. The maturity range is 3 days to 3 years, 

subject to the maximum tenor listed below.

Tenor

o The duration of time from the Effective Date to the Maturity Date Tenors will be support for 

any duration greater than 0 month to 12 months.

o Listed Tenors, also referred to as On-the-Run, means whole year Spot Starting or Same Day 

Starting Instruments with a Tenor of an integer number of months.

o Other Tenors means any Tenors other than the Listed Tenors.

Floating Reset Dates

o Dates utilized to determine the Floating Rate amount for the interest accrual period during the 

Tenor of the Instrument. Except in the case of a Stub Period, the Reset Date is adjusted 

business days dependent on the currency prior to the Roll Date for that interest accrual 

period.

First Period Fixing Date

o The Fixed Rate for the first interest period is fixed on the Trade Date, and the Floating Rate 

for the first interest period is fixed 2 business days prior to the Effective Date.

Trade Types

o The Platform may support the following trade types:

 Outrights

• An Outright swap is where one party is the payer of the fixed rate and 

receiver of the floating rate and the other party is the receiver of the fixed 

rate and payer of the floating rate.

 Switches also known as Spreads

• These are the simultaneous purchase and sale of two different Tenors of 

the yield curve (e.g. 3x6 by 9x12).

Instrument Minimum and Incremental Size.

o Minimum notional size is dependent on currency and tenor.

o Block Trades. Minimum notional size as stated by the Commission and increments 

Dependent on currency and tenor.

Quoting Convention

o Outrights are quoted in interest rate yield in minimum of 1/40th of a basis point increments.

o Spreads/Switches will be quoted in basis points dependent in multiples of the increments of 

the underlying Outrights.

Last Trading Day

o Spot Starting

 Close of business on Trade Date.

o Forward Starting
80

 Close of business three business days prior to the Effective Date of the swap.

Final Settlement Price

o Multiple payments take place during the term of the swap. Settlement price is based on the 

following factors, which must be specified by the parties:

 Interest rate, interest rate benchmark, notional amounts of the swap, Payment 

Frequency, Day Count Convention, Business Day Convention, Roll Day 

Convention, Spread (if any), Floating Rate Day Count Fraction, Floating Reset 

Dates, Discount Rate, Discount Rate Day Count Fraction and FRA 

Discounting/FRA Yield Discounting.

Additional Payments/Fees

o None.

Clearing

o Contracts are eligible to be cleared at CME, LCH.Clearnet and JSCC.

Block Trades must occur outside the Order Book and in a quantity that meets or exceeds Appropriate 

Minimum Block Sizes set by the Commission.
81

Rule 801(4) — Overnight Index Swaps (0IS)

Contract 

Specification

Details

Product Description An Overnight Index Swap is an interest rate swap for which settlement is in the 

form of periodic fixed interest payments and periodic floating interest payments 

based on an overnight rate being exchanged for a fixed interest rate over a term to 

maturity. The interest rate payments are exchanged for a specified period based 

on a notional amount. 

Currencies The interest rate cash flows are net settled in the following major currencies on 

fixing date:

USD

EUR

GBP

Trading 

Conventions

• Buyer (Payer) pays fixed interest rate and receives floating interest rate.

• Seller (Receiver) receives fixed interest rate and pays floating interest rate. 

Upfront Payment 

Dates

• USD – T+1 through maturity

• EUR – T+1 through maturity

• GBP – T+1 through maturity

Settlement 

Convention

• USD – T+1

• EUR – T+1

• GBP – T+1

Swap Leg 

Conventions

The terms of Fixed vs. Floating Interest Rate Swaps are based on a number of 

combinations of the criteria below.

• Fixed Leg

o Payment Frequency

 At Maturity Date, Annually, semi-annual, Quarterly, or 

monthly.

o Day Count Convention

 30/360, Actual/360, Actual/365.FIXED, 

Actual/Actual.ISDA, 30E/360, 30E/360.ISDA, 

Actual/Actual.ICMA

o Holiday Calendar

 Applied in accordance for the country currency denoted for 

the instrument

o Business Day Convention

 Modified Following with adjustment to period end dates. 

Business days in this convention must be valid business 

days on both the calendars (EUTA, GBLO, USNY). If not, 

it will be the next day that is a business day on both 

calendars.

o Leg Pay Date Offset:

 USD – 2D

 EUR – 1D

 GBP – 0D

o Fixed Rate

 The traded interest rate yield or basis points on Trade 

Date

• Floating Leg

o Reset Frequency
82

Contract 

Specification

Details

 Daily

o Day Count Convention

 30/360, Actual/360, Actual/365.FIXED, 

Actual/Actual.ISDA, 30E/360, 30E/360.ISDA, 

Actual/Actual.ICMA

o Holiday Calendar

 Applied in accordance for the country currency denoted for 

the instrument

o Business Day Convention

 Modified Following with adjustment to period end dates. 

Business days in this convention must be valid business 

days on both calendars (EUTA, GBLO, USNY). If not, it 

will be the next day that is a business day on both 

calendars.

o Leg Pay Date Offset:

 USD – 2D

 EUR – 1D

 GBP – 0D

o Overnight Rate

 EUR-EONIA-OIS-COMPOUND, GBP-WMBA-SONIACOMPOUND, USD-Federal Funds-H.15-OISCOMPOUND

Trade Date The date on which the parties enter into the Swap transaction. 

Effective Date The first date from which fixed and floating interest amounts accrue. It is also 

referred to as the Start Date or the Value Date. The Effective Date of the Swap 

must be a business day subject to the appropriate Business Day Convention.

Trade Start Type • Spot Starting

o A swap whose Effective Date is 2 business days from the Trade 

Date (T+2).

• Forward Starting

o A swap whose Effective Date is anything after the Effective Date 

for a Spot Starting swap.

• Same Day Starting

o A swap whose Effective Date is the Trade Date (T+0).

• Day +1 Starting

o A swap whose Effective Date is the Trade Date (T+1).

Maturity Date The final date until which Fixed and Floating amounts accrue. The Maturity Date 

may also be referred to as the Termination Date or End Date.

Tenor The duration of time from the Effective Date to the Maturity Date. The Exchange 

will support Tenors of any duration greater than 0 years to 30 years.

• Listed Tenors, also referred to as On-the-Run, means whole year Spot 

Starting or Same Day Starting Instruments with a Tenor of 1 through 15, 

20, 25, and 30 years.

• Other Tenors means any whole year Tenors other than the Listed Tenors 

and any partial year Tenor.

Roll Day 

Convention

The date used for determining all fixed and floating Reset Dates. Roll Days define 

the beginning and end of Fixed and Floating interest accrual periods.

• For On-the-Run Instruments, the Roll Day is the same date of the month as
83

Contract 

Specification

Details

the Effective Date. For Off-the-Run Instruments, it can be any date of the 

month, subject to the provisions of the Business Day Convention. Roll Day 

marks the start of a new interest accrual period, and is the date on which a 

Reset Rate takes effect.

Floating Reset 

Dates

Dates utilized to determine the Floating Rate amounts for each interest accrual 

period during the Tenor of the Instrument. Except in the case of a Stub Period, the 

Reset Date is adjusted business days dependent on the currency prior to the Roll 

Date for that interest accrual period.

First Period Fixing 

Date.

• For Spot Starting and Same Day Starting swaps, the Interest Rate for the 

first interest period is fixed on the Trade Date, for both Floating and Fixed 

Rates.

• For Forward Starting swaps, the Fixed Rate for the first interest period is 

fixed on the Trade Date, and the Floating Rate for the first interest period is 

fixed 2 business days prior to the Effective Date.

Stub Period Rate For swaps with partial year Tenors, an interest period that is shorter than the 

standard underlying Floating index interest periods may occur between the 

Effective Date and the first or last Roll Date (knows as a Stub Period). In these 

cases, the Interest Rate for such Stub Period is determined using linear

interpolation based on the two index rates that surround the Stub Period this can 

be applied either at the start or end of that period: Front or Back.

Trade Types The Platform may support the following trade types:

• Outrights

o An Outright swap is where one party is the payer of the fixed rate 

and receiver of the floating rate and the other party is the receiver 

of the fixed rate and payer of the floating rate.

• Switches also known as Spreads

o These are the simultaneous purchase and sale of two different 

Tenors of the yield curve (e.g. 2 year by 10 year).

• Butterflies

o Butterflies are the simultaneous purchase(s) and sale(s) of three 

different tenors of the yield curve (e.g. 2 year by 5 year by 10 

year).

Instrument 

Minimum and 

Incremental Size.

• Minimum notional size is dependent on currency and tenor.

• Block Trades

o Minimum notional size as stated by the Commission and 

increments dependent on currency and tenor.

Quoting Convention • Outrights are quoted in interest rate yield in minimum of 1/40th of a basis 

point increments.

• Spreads and Butterflies will be quoted in basis points dependent in 

multiples of the increments of the underlying Outrights.

Last Trading Day • Spot Starting

o Close of business on Trade Date.

• Forward Starting

o Close of business three business days prior to the Effective Date 

of the swap.
84

Contract 

Specification

Details

Additional 

Payments/Fees

• None.

Clearing • Contracts are eligible to be cleared at CME, LCH.Clearnet and JSCC.

Block Trades • Block Trades must occur outside the Order Book and in a quantity that 

meets or exceeds Appropriate Minimum Block Sizes set by the 

Commission. 
85

Rule 801(5) — Interest Rate Options

Interest Rate Options contracts cover the following product areas:

• Interest Rate Options

• Swaptions

• Inflation Swaps

• Inflation Rate Options

• Exotic Options and Swaps

Currencies

Interest Rate Options

USD

EUR

GBP

Swaptions

USD

EUR

GBP

Inflation Swaps

EUR

GBP

Inflation Rate Options

USD

EUR

GBP

Exotic Options and Swaps

USD

EUR

GBP

Specifications

Option Type

o Interest Rate Swaption

 Type

• Payer – A buyer of a payer Swaption has the option to pay the 

underlying swap at the agreed price

• Receiver – A buyer of a receiver Swaption has the option to receive the 

underlying swap at the agreed price

 Term – The future length of the swap

 Exercise – The date at which the option can be exercised on

 Underlying Swap

• Fixed Leg

o Fixed Interest rate

• Floating Leg

o Underlying benchmark

• Optional knockout clause

o Interest Rate Options

 Type

• Cap – The buyer of a Cap option receives the payments at the end of 

each period in which the underlying interest rate exceeds an agreed 

strike price

• Floor – The buyer of a Floor option receives the payments at the end of 

each period in which the underlying interest rate is below an agreed 

strike price

 Underlying Interest Rate
86

• Single Underlying Rate – Single underlying interest rate as listed in the 

Interest Rate benchmarks

• Spread – Spread between 2 underlying interest rates as listed in the 

interest rate benchmarks

 Strike

 Expiry Date

 Convention

• Payment Frequency

o Monthly

o Quarterly

o Bi-Annually

o Annually

• Payment rate

o Digital

o Linear

 Payment currency

 Optional no call period – must be an agreed number of calendar days

 Option premium

 Optional reset period – must be an agreed number of calendar days

 Start Type

• Immediate

• Forward

o Exotic Options and Swaps

 Type

• Buyer – The buyer of the swap receives a series of payments in relation 

to one agreed swap leg (leg 1) and makes a series of payments based 

on another agreed swap leg (leg 2)

• Seller – The seller of the swap makes a series of payments in relation to 

one agreed swap leg (leg 1) and receives a series of payments based on 

another agreed swap leg (leg 2)

 Tenor

 Leg 1

• Rate type

o Fixed – agreed spread

o Floating

 Single Underlying Rate – Single underlying interest rate 

as listed in the Interest Rate benchmarks

 Spread – Spread between 2 underlying interest rates as 

listed in the interest rate benchmarks

• Currency

• Optional agreed spread

• Optional agreed rate range

• Optional cap

• Optional floor

 Leg 2

• Rate type

o Fixed – agreed spread

o Floating – Floating

 Single Underlying Rate – Single underlying interest rate 

as listed in the Interest Rate benchmarks

 Spread – Spread between 2 underlying interest rates as 

listed in the interest rate benchmarks

• Currency

• Optional agreed spread

• Optional agreed rate range
87

• Optional cap

• Optional floor

 Optional reset period – must be an agreed number of calendar days

 Optional break clause

 Optional correlation factor – This will be a mathematical formula on which the 

payout of the trade will be based. This formula will be agreed at the time of 

trade.

 Start Type

• Immediate

• Forward

 Optional coupon

 Optional lockout period

o Inflation Swap

 Inflation Swap – The buyer of an inflation swap pays a fixed interest rate and 

receives the agreed floating inflation rate

• Tenor

• Fixed Rate (Traded Price)

• Inflation Rate benchmark – this can be any inflation benchmark that 

settles in the listed currencies

• Optional forward start

o Inflation Option

 Types

• Cap – The buyer of a cap option receives the right to receive a payment 

should the rate of the agreed underlying index rise above a certain level

• Floor – The seller of a floor option receives the right to receive a 

payment should the rate of the agreed underlying index fall below a 

certain level

 Tenor

 Exercise Type

• American

• European

• Bermudan

 Premium (Traded Price x agreed notional)

 Premium Type

• Spot

• Annuity

• Forward

Payment Frequency

o Interest Rate Swaptions – the payment frequency will be an agreed, valid, calendar integer

o Interest Rate Options – the payment frequency will be an agreed, valid, calendar integer

o Exotic Options and Swaps – the payment frequency will be an agreed, valid, calendar integer

o Inflation Swaps – the payment frequency will be an agreed, valid, calendar integer

o Inflation Rate Options – the payment frequency will be an agreed, valid, calendar integer

Day Count Convention

o Interest Rate Swaptions

 30/360

 Act/360

 Act/365

 360/360

 30E/360

 AFI/365

 ACT/366

 ACT/ACT

o Interest Rate Options
88

 ACT/360

 ACT/365

 360/360

 30/360

 30E/360

 AFI/365

 ACT/366

 ACT/ACT

o Exotic Options and Swaps

 ACT/360

 ACT/365

 360/360

 30/360

 30E/360

 AFI/365

 ACT/366

 ACT/ACT

o Inflation Swaps

 ACT/360

 ACT/365

 360/360

 30/360

 30E/360

 AFI/365

 ACT/3613

 ACT/ACT

Holiday Calendar Conventions

o Interest Rate Swaptions

 ABU DHABI

 SYDNEY

 TORONTO

 PRAGUE

 COPENHAGEN

 HONG KONG

 BUDAPEST

 LONDON

 TEL AVIV

 JAFFA

 TOKYO

 WELLINGTON

 SEOUL

 BANGKOK

 TARGET

 WARSAW

 MOSCOW

 RIYADH

 SINGAPORE

 ISTANBUL

 NEW YORK

 OSLO

 STOCKHOLM

 JOHNNESBURG

 KUALA LUMPAR

o Interest Rate Options

 ABU DHABI
89

 SYDNEY

 TORONTO

 PRAGUE

 COPENHAGEN

 HONG KONG

 BUDAPEST

 LONDON

 TEL AVIV

 JAFFA

 TOKYO

 WELLINGTON

 SEOUL

 BANGKOK

 TARGET

 WARSAW

 MOSCOW

 RIYADH

 SINGAPORE

 ISTANBUL

 NEW YORK

 OSLO

 STOCKHOLM

 JOHNNESBURG

 KUALA LUMPAR

o Exotic Options and Swaps

 ABU DHABI

 SYDNEY

 TORONTO

 PRAGUE

 COPENHAGEN

 HONG KONG

 BUDAPEST

 LONDON

 TEL AVIV

 JAFFA

 TOKYO

 WELLINGTON

 SEOUL

 BANGKOK

 TARGET

 WARSAW

 MOSCOW

 RIYADH

 SINGAOPRE

 ISTANBUL

 NEW YORK

 OSLO

 STOCKHOLM

 JOHNNESBURG

 KUALA LUMPAR

o Inflation Swaps

 NEW YORK

 LONDON

 EUROPE

 Australia

o Inflation Rate Options
90

 NEW YORK

 LONDON

 EUROPE

Business Day Conventions

o Interest Rate Swaptions

 Modified

 Modified Following

o Interest Rate Options

 Modified

 Modified Following

o Exotic Options and Swaps

 Modified

 Modified Following

o Inflation Swaps

 Modified

 Modified Following

o Inflation Rate Options

 Modified

 Modified Following

Effective Date

o Interest Rate Swaptions – The effective date will be a valid business day

o Interest Rate Options – The effective date will be a valid business day

o Exotic Options and Swap – The effective date will be a valid business day

o Inflation Swaps – The effective date will be a valid business day

o Inflation Rate Options – The effective date will be a valid business day

Maturity Date

o Interest Rate Swaptions – The maturity date will be a valid calendar day

o Interest Rate Options – The maturity date will be a valid calendar day

o Exotic Options and Swaps – The maturity date will be a valid calendar day

o Inflation Swaps – effective date + tenor of swap

o Inflation Rate Options – Not applicable

Tenors

o Interest Rate Swaptions 0 – 100 years inclusive

o Interest Rate Options – 0 – 100 years inclusive

o Exotic options and swaps – 0 – 100 years inclusive

o Inflation Swap – 0 – 100 years inclusive

o Inflation Rate Options 0 – 100 years inclusive

Roll Dates

o Interest Rate Swaptions

 Calendar dates

 End of month

 IMM Dates

o Interest Rate Options

 Calendar dates

 End of month

 IMM Dates

o Exotic Options and Swaps

 Calendar dates

 End of month

 IMM Dates

 None

o Inflation Swaps – 0 – 50 years inclusive

o Inflation Rate Options – 0 – 50 years inclusive
91

Fixing Dates

o Interest Rate Swaptions – The fixing date will be a valid business day

o Interest Rate Options – The fixing date will be a valid business day

o Exotic Options and Swaps – The fixing date will be a valid business day

o Inflation Swaps – The fixing date(s) will be a valid calendar day

o Inflation Options – The fixing date(s) will be a valid calendar day

Settlement

o Interest Rate Swaptions

 Swaptions will be settled by either

• Cash

• Delivery of the swap

• Part Cash; Part Delivery

 The settlement date(s) will be valid business days

o Interest Rate Options

• All options contracts are cash settled

• The settlement date(s) will be valid business days

o Exotic Options and Swaps

 Contracts will be settled by either

• Cash

• Delivery of the swap

• Part Cash; Part Delivery

 The settlement date(s) will be valid business days

o Inflation Swaps – Are cash settled in line with the payment frequency

o Inflation Rate Options – Are cash settled in line with the payment frequency

Contract Size

o Minimum and Incremental Sizes

 Interest Rate Swaptions

• The minimum size for a Swaption is 1,000 of the agreed currency of the 

trade

• There is no minimum incremental size for a Swaption

 Interest Rate Options

• The minimum size for an option is 1,000 of the currency of the underlying 

index of the trade

• There is no minimum incremental size for an option

 Exotic Options and Swaps

• The minimum size for an instrument in this category is 1,000 units of the 

currency of the underlying index of the trade

• There is no minimum incremental size for instruments in this category

 Inflation Swaps

• The minimum size for an instrument in this category is 1,000 units of the 

currency of the underlying index of the trade

• There is no minimum incremental size for instruments in this category

 Inflation Rate Options

• The minimum size for an instrument in this category is 1,000 units of the 

currency of the underlying index of the trade

• There is no minimum incremental size for instruments in this category

o Accreting Size – Any product can be traded on

 An accreting basis

 A non-accreting basis

Quoting Convention

o Interest Rate Swaptions are all quoted in basis points

o Interest Rate Options are all quoted in basis points

o Exotic Options and Swaps are all quoted in basis points
92

o Inflation Swaps are all quoted in basis points

o Inflation Options are all quoted in basis points

Benchmark Interest Rates

o Contracts will be limited to all or a subset of the following underlying benchmark indices:

 EBOR

 BBR

 CDOR

 LIBOR

 PRIBOR

 CIBOR

 CIBOR2

 HIBOR

 BUBOR

 TELBOR01

 WIBOR

 MOSPRIME

 SAIBOR

 TRILIBOR

 NIBOR

 STIBOR JIBAR

 EURIBOR

 ISDAFIX

 ICAP Listed Interest Rates Swaps

Minimum and Incremental Price

o Interest Rate Swaptions

 There is no minimum price

 There is no minimum incremental price

o Interest Rate Options

 There is no minimum price

 There is no minimum incremental price

o Exotic Options and Swaps

 There is no minimum price

 There is no minimum incremental price

o Inflation Swaps

 There is no minimum price

 There is no minimum incremental price

o Inflation Options

 There is no minimum price

 There is no minimum incremental price

Reporting

o All Interest Rate Options trades are reported in accordance with NFA and SDR requirements

Clearing

o Interest Rate Options traded on ICAP SEF are not cleared.
93

The following information has been submitted to the Commission subject to a request for confidential 

treatment in accordance with Commission Regulation 145.9 in order to prevent disclosure of IGDL’s 

confidential commercial information upon a request under the Freedom of Information Act. IDGL 

requests that the recipient limit distribution to those individuals with a need to know.

ACTIVE 211634036