Refinitiv US SEF LLC

28 Liberty Street – 57th Floor

New York, NY 10008

www.refinitiv.com

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November 21, 2022 

SUBMITTED VIA PORTAL

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

Re: Submission 22-02: Refinitiv US SEF LLC – Amendments to Rulebook 

Ladies and Gentlemen:

Pursuant to Commodity Futures Trading Commission (“Commission”) Regulation 40.6(a), 

Refinitiv US SEF LLC (“RSEF”) hereby self-certifies the amendments to its Rulebook identified 

in Exhibit A. The Rulebook has been amended in order to reflect certain amendments to RSEF’s 

requirements related to the reporting counterparty hierarchy under Commission Regulation 45.8, 

and to clarify requirements when a Participant’s legal entity identifier is changed in any way. The 

amended Rulebook will become effective on December 6, 2022. 

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

applicable provisions of the Commodity Exchange Act (“CEA”) is attached hereto as Exhibit A, 

and the amendments showing changes against the version submitted to the Commission in 

Submission 21-01-A on February 17, 2021, is attached hereto as Exhibit B. 

RSEF hereby certifies that: (i) the amended Rulebook complies with the CEA and the 

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

concurrently posted on RSEF’s website. No substantive opposing views were expressed with 

respect to the amendments to the Rulebook. 

Please contact me using the information below if you have any questions regarding these 

amendments to the Rulebook. 

Michelle Weiler

318 West Adams Street

Chicago, IL 60606 

Phone: (847) 826 8080 

Email: Michelle.Weiler@lseg.com

 
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Sincerely, 

Michelle Weiler

Chief Compliance Officer

cc: Nancy Markowitz, Deputy Director, Division of Market Oversight, Exchange and Data

Repository Branch

Swati Shah, Special Counsel, Division of Market Oversight

(Commodity Futures Trading Commission)
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EXHIBIT A

Explanation and Analysis of Material Amendments

Summary: The Rulebook has been amended in order to reflect certain amendments to 

RSEF’s requirements related to the reporting counterparty hierarchy under Commission 

Regulation 45.8, and to clarify requirements when a Participant’s legal entity identifier is 

changed in any way. The amended Rulebook showing changes against the version submitted

to the Commission in Submission 21-01-A on February 17, 2021, is attached hereto as Exhibit 

B. 

Capitalized terms used but not otherwise defined herein have the meanings assigned to

them in the Rulebook. 

Amendment and Explanation Relevant Law, Regulation or

Guidance

Rule 307

Added requirement that participants must inform Refinitiv SEF 

of any amendments to LEIs

Core Principle 2

Rule 402(a)(4)

Clarifies the reporting hierarchy for circumstances where 

Commission Regulation 45.8 requires the counterparties to 

agree which counterparty will be the reporting counterparty 

Commission Regulation 45.8

Various Rules 

Removed references to “CFTC Interim Compliant Identifier”

and “CICI” in order to reference only “Legal Entity Identifier”

Core Principle 2
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EXHIBIT B

Rulebook Amendments