REFINITIV US SEF LLC

RULEBOOK

THIS REFINITIV US SEF RULEBOOK IS SUBJECT TO

CHANGE WITHOUT NOTICE. THE RULES HEREIN, AND ANY

REVISIONS TO BE MADE, ARE CONDITIONAL UNTIL

APPROVED OR DEEMED APPROVED BY THE CFTC.

December 8, 2020

March 2, 2021
BY BECOMING A REFINITIV SWAP EXECUTION FACILITY (SEF) PARTICIPANT, ACCESSING

THE PLATFORM OR ENTERING ANY ORDER OR SUBMITTING ANY CONTACT INTO THE

PLATFORM, WHETHER DIRECTLY OR THROUGH AN INTERMEDIARY, AND WITHOUT ANY

NEED FOR ANY FURTHER ACTION, UNDERTAKING OR AGREEMENT, A PARTICIPANT AND

ITS AUTHORIZED PERSON(S), AND THE CLIENTS AND CUSTOMERS OF ANY

PARTICIPANT, AND ANY SPONSORED PERSON, ANY ISV, AGREE:

(I) TO BE BOUND BY, AND COMPLY WITH, THE SEF RULES AND OBLIGATIONS, AND

APPLICABLE LAW, IN EACH CASE TO THE EXTENT APPLICABLE TO IT;

(II) TO BECOME SUBJECT TO THE JURISDICTION OF THE SEF WITH RESPECT TO ANY

AND ALL MATTERS ARISING FROM, RELATED TO, OR IN CONNECTION WITH, THE

STATUS, ACTIONS OR OMISSIONS OF SUCH PERSON;

(III) TO PERMIT THE SEF AND ANY REGULATORY SERVICES PROVIDER AUTHORIZED

TO ACT ON BEHALF OF THE SEF TO ACCESS ANY AND ALL INFORMATION RELEVANT TO

ACTIVITIES RELATED TO THE SEF BUSINESS;

(IV) TO ASSIST THE SEF IN COMPLYING WITH ITS LEGAL AND REGULATORY

OBLIGATIONS, COOPERATE WITH THE SEF AND THE CFTC IN ANY INQUIRY,

INVESTIGATION, AUDIT, EXAMINATION OR PROCEEDING; AND

(V) THAT THE SEF IS AUTHORIZED TO PROVIDE INFORMATION REGARDING SUCH

PERSON TO THE REGULATORY SERVICES PROVIDER, THE CFTC OR ANY SELFREGULATORY ORGANIZATION.
© Refinitiv 20202021. All Rights Reserved.

Refinitiv, by publishing this document, does not guarantee that any information contained herein is and will remain accurate or

that use of the information will ensure correct and faultless operation of the relevant service or equipment. Refinitiv, its agents

and employees, shall not be held liable to or through any user for any loss or damage whatsoever resulting from reliance on the

information contained herein.

This document contains information proprietary to Refinitiv and may not be reproduced, disclosed, or used in whole or part

without the express written permission of Refinitiv.

Any Software, including but not limited to, the code, screen, structure, sequence, and organization thereof, and Documentation

are protected by national copyright laws and international treaty provisions. This manual is subject to U.S. and other national

export regulations.

Nothing in this document is intended, nor does it, alter the legal obligations, responsibilities or relationship between yourself

and Refinitiv as set out in the contract existing between us.

FX Global Code

The FX Global Code1 sets out globally recognized principles of good practice in the wholesale foreign exchange market

(“FX Market”) and serves as an essential reference for market participants when conducting business in the FX Market and

when developing and reviewing internal procedures.

The FX Global Code is supported by a Statement of Commitment that provides a means by which market participants can signal

their intention to adopt, and adhere to, the FX Global Code. The signing of a Statement of Commitment represents that a market

participant (i) has made an independent determination to support the FX Global Code, (ii) is committed to conducting its FX

activities in accordance with the FX Global Code’s principles and (ii) confirms that it has taken appropriate steps, based on the size

and complexity of its activities, and the nature of its engagement in the FX Market, to align its activities with the FX Global Code

principles.

In relation to SEF products, the SEF supports though does not mandate the signing of a Statement of Commitment by its

Participants (as defined herein) as a condition of access to those products. Participants are responsible for deciding to what

extent they should voluntarily adopt and implement the FX Global Code guidelines, and are responsible for deciding whether their

market counterparties need to confirm that they have signed a Statement of Commitment, and then for performing any associated

due diligence. For example, a Participant can confirm directly with a potential market counterparty that such counterparty has

signed a Statement of Commitment, or use an FX Global Code public register for these purposes, such as the public register

maintained by CLS.2

Refinitiv (i.e., the SEF’s ultimate parent) has signed a Statement of Commitment to the FX Global Code, formally pledging

adherence to the Code’s standards to promote integrity, fairness, transparency and the effective functioning of the global foreign

exchange markets. Refinitiv has played an active role in the development of the FX Global Code through its membership in the

Market Participants Group and through participation in regional committees, including the London Foreign Exchange Joint Standing

Committee, the Federal Reserve Bank of New York Foreign Exchange Committee, the Tokyo Foreign Exchange Market

Committee, the Canadian Foreign Exchange Committee, and the Australian Foreign Exchange Committee.

For the avoidance of doubt, nothing in the FX Global Code supersedes any provision(s) of the SEF Rules, CFTC Regulations or

the Commodity Exchange Act (in each case, as defined herein).

1

 FX Global Code, available at: https://www.globalfxc.org/fx_global_code.htm.

2

 CLS, FX Global Code – public register, available at: https://www.globalfxc.org/fx_global_code.htm.

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Contents

Chapter 1 Definitions 1

Rule 101 Definitions 7

Rule 102 Rules of Construction 15

Chapter 2 SEF Ownership and Governance 16

Rule 201 Ownership 16

Rule 202 Board 16

Rule 203 Officers 16

Rule 204 Qualifications of Directors, Disciplinary Panel Members, Committee Members and Officers 16

Rule 205 Chief Compliance Officer 17

Rule 206 Standing Committees 19

Rule 207 Regulatory Oversight Committee 19

Rule 208 Additional Board Committees and SEF Panels 20

Rule 209 Emergency Rules 20

Rule 210 Conflicts of Interest and Misuse of Material, Non-Public Information 21

Rule 211 Information-Sharing Agreements 23

Rule 212 Services Agreement with a Regulatory Services Provider 23

Rule 213 Services Agreement with a Technology Services Provider 23

Chapter 3 Participants 24

Rule 301 Criteria for Becoming a Participant 24

Rule 302 Participant Application Process 25

Rule 303 Trading Privileges 26

Rule 304 Access to the Platform 26

Rule 305 Dues, Assessments and Fees 26

Rule 306 Participant Representatives 27

Rule 306.A Authorized Persons 27

Rule 306.B Authorized Representatives 27

Rule 307 Identification of Authorized Persons 27

Rule 308 Recording of Communications 28

Rule 309 Notices to Participants 28

Rule 310 Communications between the SEF and Participants 28

Rule 311 Application of the SEF Rules and Jurisdiction 28

Rule 312 Description of Participant’s Status 29

Rule 313 Death or Dissolution of a Participant 29

Rule 314 Withdrawal of Participant 29

Rule 315 Compliance with the CEA 29

Rule 316 Sponsored Access 29

Chapter 4 SEF Services 30

Rule 401 Real-Time Public Reporting 30

Rule 402 Regulatory Reporting 31

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Rule 403 Maintenance of Books and Records by the SEF 32

Rule 404 Transaction Confirmations 33

Rule 405 Audit Trail Program 34

Rule 406 Monitoring of Trading and Trade Processing 34

Rule 407 Publication of Trading Information 34

Chapter 5 Obligations of Participants 35

Rule 501 Duties and Responsibilities of Participants 35

Rule 502 Required Disclosures to the SEF 35

Rule 503 Inspections by the SEF 36

Rule 504 Minimum Requirements for Participants 37

Rule 505 Recordkeeping Requirements 37

Rule 506 Confidentiality of Financial and Other Information 37

Rule 507 Authority to Report 37

Rule 508 Brokers and Account Managers 37

Rule 509 Treatment of Customer Funds and Securities 38

Rule 510 Disclosure Requirements; Know Your Counterparty Requirements 38

Rule 511 Information Regarding Orders 38

Rule 512 Customer Type Indicator (CTI) Codes 38

Rule 513 Canceled Trades & Amended Trade Information 38

Chapter 6 Supported Transactions 39

Rule 601 General 39

Rule 602 Block Trades 39

Rule 603 Prime Broker Trades 40

Chapter 7 Execution Methods 40

Rule 701 General 40

Rule 702 Central Limit Order Book (“CLOB”) 40

Rule 703 Request For Quote Platform (“RFQ Platform”) 42

Rule 704 Request For Stream Platform (“RFS Platform”) 42

Rule 705 Confirmation Procedures and Records. 43

Rule 706

Rule 707

Legal Certainty for SEF Trades.

Post-Trade Anonymity

43

43

Chapter 8 [Reserved] 44

Chapter 9 Trading Practices and Business Conduct 44

Rule 901 Scope 44

Rule 902 Procedures 44

Rule 903 Business Days and Trading Hours 44

Rule 904 Rule Violations 44

Rule 905 Fraudulent Acts Prohibited 44

Rule 906 Fictitious, Wash or Non-Competitive Transactions Prohibited 44

Rule 907 Market Disruption Prohibited 45

Rule 908 Manipulation and Fraudulent Conduct Prohibited 45

Rule 909 Disruptive Trading Practices Prohibited 45

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Rule 910 Abusive Trading Practices Prohibited 45

Rule 911 Prohibition of Misstatements 45

Rule 912 Acts Detrimental to Welfare of the SEF Prohibited 45

Rule 913 Adherence to Law 45

Rule 914 Supervision 46

Rule 915 Misuse of the Platform 46

Rule 916 Withholding Orders Prohibited 46

Rule 917 Priority of Customers’ Orders 46

Rule 918 Handling of Customer Orders 46

Rule 919 Disclosing Orders Prohibited 46

Rule 920 [Reserved] 46

Rule 921 Pre-arranged and Noncompetitive Trades Prohibited 46

Rule 922 Responsibility For Customer Orders 46

Rule 923 Discretionary Orders 47

Rule 924 Position Limits 47

Rule 925 Exemptions from Position Limits 47

Rule 926 Position Accountability 47

Rule 927 Platform Access Restrictions 47

Rule 928 Pre-Execution Credit Checks 48

Rule 929 Risk Controls for Trading 48

Rule 930 [Reserved] 48

Rule 931 LIMITATION OF LIABILITY, NO WARRANTIES 48

Chapter 10 Disciplinary Rules 49

Rule 1001 General 50

Rule 1002 Investigations and Investigation Reports 51

Rule 1003 Disciplinary Panels 51

Rule 1004 Review of Investigatory Report 52

Rule 1005 Notice of Charges 52

Rule 1006 Answer to Notice of Charges 52

Rule 1007 Settlements 53

Rule 1008 Respondent Review of Evidence 54

Rule 1009 Hearings 54

Rule 1010 Decision of Hearing Panel 55

Rule 1011 Sanctions 56

Rule 1012 Right to Appeal 56

Rule 1013 Summary Fines 56

Rule 1014 Emergency Summary Suspensions and Other Summary Actions 57

Rule 1015 Rights and Responsibilities after Suspension or Termination 58

Rule 1016 Notice to the Respondent, the Regulatory Services Provider and the Public 58

Chapter 11 Arbitration Rules 58

Rule 1101 Disputes Subject to Arbitration 58

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Rule 1102 Initiating an Arbitration Claim 59

Chapter 12 Miscellaneous 59

Rule 1201 SEF Personnel: Trading and Misuse of Material, Non-Public Information 59

Rule 1202 No Endorsement of Opinions, Research or Recommendations 60

Rule 1203 Not a Party 60

Rule 1204 No Advice 60

Rule 1205 Gifts and Gratuities 60

Rule 1206 Market Data and Intellectual Property 61

Rule 1207 Extension or Waiver of Rules 61

Rule 1208 Effect of Amendment, Repeal or New Rule 61

Rule 1209 Antitrust Considerations 62

Rule 1210 Governing Law, Jurisdiction and Dispute Resolution 62

Chapter 13 Contract Terms and Conditions 62

Rule 1301 Non-Deliverable Forwards 62

Rule 1302 Cross-Currency NDFs 67

Rule 1303 FX Options 71

Annex A Appropriate Minimum Block Sizes 73

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Chapter 1 – Definitions

RULE 101 DEFINITIONS

When used in this Rulebook the following terms shall have the respective meanings as follows:

“Account Manager” means a Person that acts as an agent to buy or sell Swaps on the Platform in the name or on

behalf of another Person. An Account Manager may also be a Participant, and may be acting through another Account

Manager if the Swap is intermediated.

“Affected Person” means a SEF applicant whose admission application is declined or is conditioned or a Person

whose status as a Participant is terminated, in each case as set forth in SEF Rule 302(g).

“Affiliate” means, with respect to any Person, any Person who, directly or indirectly through one or more intermediaries,

Controls, is Controlled by, or is under common Control with, such other Person.

“Applicable Law” means any foreign, federal (including the CFTC), state or other law, rule, regulation, interpretation or

action of relevant regulatory organizations (including the National Futures Association) or self-regulatory organizations

applicable to the access to and use of the Platform, including the conduct of Swaps through the Platform.

“Appropriate Minimum Block Size” means the minimum notional or principal amount established from time to time by

the CFTC for a category of Swap that qualifies as a block trade pursuant to CFTC Regulation 43.6. The Appropriate

Minimum Block Size is published by the CFTC or its designee from time to time in accordance with CFTC Regulations

43.6 and 43.7 and is reproduced herein in Annex A.

“Authorized Person” means an employee or other person under Participant’s control designated by Participant or one

of Participant’s administrators to be able to access and use the Platform and SEF Services on Participant’s behalf

pursuant to Rule 306.A. An Authorized Person can also mean a computer or system accessing the SEF via a program

interface on behalf of such Participant.

“Authorized Representative” means any Person who is authorized by a Participant to represent the Participant in SEF

matters pursuant to Rule 306.B.

“Block Trade” means a privately negotiated Swap that (1) involves a Swap that is listed by the SEF; (2) occurs away

from the Platform pursuant to the SEF Rules; (3) has a notional or principal amount at or above the Appropriate

Minimum Block Size applicable to such Swap; and (4) is reported subject to the SEF Rules and the CFTC Regulations,

including the appropriate time delay requirements set forth in CFTC Regulation § 43.5.

“Board” means the Board of Directors of the SEF, which manages the SEF and is constituted from time to time in

accordance with the SEF LLC Agreement.

“Business Day” means the twenty-four hour day, on all days except Saturdays, Sundays, and legal holidays, in New

York, NY.

“CFTC” or “Commission” means the U.S. Commodity Futures Trading Commission or any successor regulatory body.

“CFTC Regulations” means the rules and regulations promulgated by the CFTC, as amended, as well as any

guidance, no-action letters or other form of interpretation issued by the CFTC.

“Chief Compliance Officer” means the individual appointed by the Board as the SEF’s Chief Compliance Officer.

“Chief Executive Officer” means the individual appointed by the Board as the SEF’s Chief Executive Officer.
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“CICI” means a CFTC Interim Compliant Identifier.

“Cleared Swap” means a Swap that is subject to the Clearing Requirement or any Swap that is intended by a

Participant to be submitted to a Derivatives Clearing Organization for clearing contemporaneously with Execution.

“Clearing Member” means a member of a Derivatives Clearing Organization that is authorized to clear trades in any or

all Swaps for a Participant or its Clients or Customers.

“Clearing Requirement” means the requirement to clear such swaps as the CFTC has determined must be cleared

pursuant to Section 2(h) of the CEA and the CFTC’s rules and regulations promulgated thereunder.

“Client” means a Person (including a Prime Broker) that: (i) granted in writing (either stand-alone or as part of a broader

instrument) to an Account Manager investment authority or trading authority to send RFQs, to enter Orders and/or

execute Swaps on behalf of and in the name of such Person; and (ii) is a Counterparty to aSwap.

“Commodity Exchange Act” or “CEA” means the Commodity Exchange Act, as amended from time to time.

“Commodity Interest” has the meaning ascribed to it in CFTC Regulation § 1.3(yy).

“Confirmation Data” means all of the terms of a Swap matched and agreed upon by the counterparties in confirming

the Swap.

“Continuation Data” means the data required to be reported to a Swap Data Repository in CFTC Regulation § 45.3(b),

or any successor regulation thereto.

“Contract” means any Swap, contract, agreement, or transaction approved for trading on the Platform pursuant to the

SEF Rules.

“Contract Market” has the meaning ascribed to it in CFTC Regulation § 1.3(h), or any successor regulation thereto.

“Control” means the possession, direct or indirect, of the power to direct or cause the direction of the management and

policies of a Person, whether through the ownership of securities, by contract, or otherwise. The terms “controlling” or

“controlled” shall have meanings correlative to the foregoing.

“Counterparty” means a Participant or a Participant’s Client or Customer whose Legal Entity Identifier is reported by

the Platform to an SDR as a Counterparty to a trade.

“Creation Data” has the meaning ascribed to the term “Required swap creation data” in CFTC Regulation § 45.1.

“CTI Code” means a customer type indicator code.

“Customer” has the meaning set forth in CFTC Regulation § 1.3(k).

“Customer Account” means an account carried by a Participant on behalf of a Customer.

“Derivatives Clearing Organization” means a derivatives clearing organization as defined in CFTC Regulation §

1.3(d), or any successor regulation thereto.

“Director” means any member of the Board.

“Disciplinary Action” means a disciplinary proceeding, summary imposition of fines, summary suspension or other

summary action.

“Disciplinary Panel” means the panel appointed by the Board at the recommendation of the Chief Compliance Officer

to act in an adjudicative role and fulfill various adjudicative responsibilities and duties described in Chapter 10.

“DTCC” means DTCC Data Repository (U.S.) LLC.
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“Eligible Contract Participant” shall have the meaning set forth in Section 1a(18) of the CEA and the CFTC’s rules

and regulations promulgated thereunder.

“Emergency” means any occurrence or circumstance which, in the opinion of the Board, or a person or persons duly

authorized to issue such an opinion on behalf of the Board, under circumstances and pursuant to procedures that are

specified by rule, requires immediate action, and which threatens, or may threaten, such things as the fair and orderly

trading in, or the liquidation of or delivery pursuant to, any agreements, contracts, swaps or transactions, or the timely

collection and payment of funds in connection with clearing and settlement by a Derivatives Clearing Organization,

including:

(1) Any manipulative or attempted manipulative activity;

(2) Any actual, attempted, or threatened corner, squeeze, congestion, or undue concentration of positions;

(3) Any circumstances which may materially affect the performance of agreements, contracts, swaps or

transactions, including failure of the payment system or the bankruptcy or insolvency of a Participant or any other

Person;

(4) Any action taken by any Governmental Agency, or any other Registered Entity, board of trade, market or facility

which may have a direct impact on trading or clearing and settlement; and

(5) Any other circumstance which may have a severe, adverse effect upon the functioning of a Registered Entity.

“Emergency Rules” means temporary emergency procedures and rules implemented pursuant to Rule 209.

“End-User” mean a Participant that is not a “financial entity” as defined in CEA Section 2(h)(7)(C)(i), is using the

Transaction to hedge or mitigate commercial risk as defined in CFTC Regulation § 39.6(c), and provides or causes to

be provided to a registered Swap Data Repository or, if no registered Swap Data Repository is available, the

Commission, the information specified in CFTC Regulation § 39.6(b), or any successor regulation thereto.

“End-User Exception” means the exception to the clearing requirement under CEA Section 2(h)(7)(A), as amended

from time to time.

“Execution” means an agreement by the counterparties (whether orally, in writing, electronically, or otherwise) to the

terms of the Contract that legally binds the counterparties to such terms under Applicable Law.

“FXall Group” means FX Alliance, LLC and its affiliates.

“Futures Commission Merchant” has the meaning set forth in Section 1a(28) of the CEA and the CFTC’s rules and

regulations promulgated thereunder.

“Government Agency” means any governmental entity (including the United States, a State, or a foreign government).

“Hearing Panel” means the Disciplinary Panel responsible for adjudicating disciplinary cases pursuant to a notice of

charges authorized by a Review Panel.

“Independent Software Vendor” or “ISV” means a Person that makes available to Participants a system or platform

offering smart order routing, front-end trading applications, an aggregator platform or a combination of the foregoing but

that does not provide Participants the ability to effect transactions on such system or platform.

“Interested Person” has the meaning attributed to such term in Rule 210(a).

“Intermediary Agreement” means an agreement between a Participant and a Sponsored Person, a Customer or Client

of such Participant.
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“ISV Agreement” means an agreement entered into between the SEF and an ISV setting forth the rights and

obligations of both parties.

“Legal Entity Identifier” means the unique alphanumeric code issued to Participant by a CFTC-designated utility or a

registered Swap Data Repository, as set forth in 17 C.F.R. § 45.6 or any successor regulation thereto.

“Market Regulation Department” means the Chief Compliance Officer and the individuals under the supervision of the

Chief Compliance Officer who are responsible for enforcing these SEF Rules and conducting investigations of alleged

violations of these Rules. As the term is used herein, the Market Regulation Department includes: (i) the SEF’s

compliance staff dedicated to enforcing the SEF Rules and performing services directly related to the SEF’s compliance

with Applicable Law; (ii) employees of other divisions of the SEF or its Affiliates who have certain regulatory

responsibilities with respect to the SEF; and (iii) the staff of the Regulatory Services Provider providing services to the

Company pursuant to a Regulatory Services Agreement.

“Major Swap Participant” shall have the meaning set forth in Section 1a(33) of the CEA and the CFTC’s rules and

regulations promulgated thereunder.

“NFA” means the National Futures Association.

“NFA Arbitration Program” means the arbitration program established by the NFA designed for disputes between and

among SEF Participants.

“Non-Cleared Swap” means a Swap that is not a Cleared Swap, including, for the avoidance of doubt, a Swap where at

least one Participant party is an End-User and that party elects the End-User Exception.

“Notice to Participants” means a communication sent by or on behalf of the SEF to all Participants as described in

Rule 309.

“Obligation” means all obligations of a Participant as set forth in the SEF Rules, all rules adopted by the SEF in this

Rulebook, the User Agreement, all Notices to Participants published by the SEF, interpretations, orders, procedures,

resolutions, advisories, statements of policy, decisions, notices, manuals, directives of the SEF, and other

requirements implemented by the SEF under the SEF Rules, including each term of a Contract, as well as any

contractual obligations between a Participant, Account Manager, and the SEF, including the Participant Documentation

and all amendments thereto.

“Officer” has the meaning attributed to such term in Rule 203.

“Option” has the meaning set forth in Section 1a(36) of the CEA and the CFTC’s rules and regulations promulgated

thereunder.

“Order” means either a bid or an offer for a Contract.

“Participant” means a Person (other than an ISV, except to the extent permitted under the SEF Rules) that has agreed

to the terms of these SEF Rules, the User Agreement, any Applicable Laws and regulations, and any and all other

documents referenced herein, all as may be amended from time to time, and who has completed the User Agreement.

Participants shall be granted Trading Privileges under the SEF Rules and shall be deemed to be members of the SEF

for purposes of the CEA. The term Participant includes Authorized Person(s).

“Participant Documentation” means the agreements (together with any applicable schedules, exhibits or appendices

thereto required by the SEF) in form and substance acceptable to the SEF, that are required to be executed and

delivered to the SEF before a Person may access the Platform, including, but not limited to the User Agreement as

applicable and amended from time to time by the SEF.
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“Permitted Transactions” means any Transaction that is not subject to the trade execution requirement in Section

2(h)(8) of the CEA as well as any Transaction executed on the Platform where one of the counterparties properly elects

to use the End-User Exception.

“Person” means a natural person or a juridical entity.

“Platform” means the interactive electronic trading facility and interface operated by or on behalf of the SEF as a Swap

Execution Facility, including all components thereof, on and through which Participant may (i) submit Transaction Data

to one or more other Participants and (ii) initiate and enter into Swaps. The Platform includes the SEF RFQ Platform,

the SEF RFS Platform, and the SEF Central Limit Order Book.

“Pre-Execution Communication” means a communication between two Persons for the purpose of discerning interest

in the execution of a Swap prior to execution of the Swap on the SEF, including any communication that involves

discussion of the size, side of market, or price of an Order or a potentially forthcoming Order; provided that any

communication between two Persons that involves an agreement between the parties to a Swap that legally binds the

parties to such Swap shall not be considered a Pre-Execution Communication.

“Primary Economic Terms” means all of the terms of a Swap matched or affirmed by the counterparties in verifying

the Swap, including at a minimum each of the terms included in the most recent Federal Register release by the CFTC

listing minimum primary economic terms for Swaps in the swap asset class in question. The CFTC's current lists of

minimum primary economic terms for Swaps in each Swap asset class are found in appendix 1 to CFTC Regulation

Part 45.

“Prime Broker” means a Person that provides prime brokerage services and that has authorized an Account Manager

to send RFQs, place Orders and/or enter into Swaps Transactions in the name and on behalf of such Person. Each

Prime Broker must sign documentation as may be required by the SEF from time to time.

“Prime Broker Agreement” means an agreement between a Prime Broker and a Participant that governs the

performance and settlement of a Non-Cleared Swap, including any applicable credit support and default provisions.

“Prime Broker Trade” means a Non-Cleared Swaps Transaction where one Counterparty is a Prime Broker and the

other is a Participant with which the Prime Broker has a Prime Broker Agreement.

“Proprietary Account” has the meaning ascribed to it by CFTC Regulation § 1.3(y), or any successor regulation

thereto.

“Proprietary Data and Personal Information” means, as to any Person, data or information that is related to, or that

separately discloses, business transactions, market positions or trade secrets of such Person, but does not include

Transaction Data.

“Refinitiv Group” means Refinitiv and its affiliates.

“Registered Entity” means (1) a board of trade designated as a contract market under section 5 of the CEA; (2) a

Derivatives Clearing Organization; (3) a board of trade designated as a contract market under section 5f of the CEA;

(4) a Swap Execution Facility registered under section 5h of the CEA; (5) a Swap Data Repository registered under

section 21 of the CEA; and (6) with respect to a contract that the CFTC determines is a significant price discovery

contract, any electronic trading facility on which the contract is executed or traded.

“Regulatory Oversight Committee” means the committee of the Board constituted in accordance with Rule 207.
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“Regulatory Services Agreement” means the agreement(s) between the SEF and the Regulatory Services Provider

whereby certain functions mandated under the CEA, such as market surveillance and trade practice surveillance, are

performed by to the Regulatory Services Provider.

“Regulatory Services Provider” means the organization, if any, which provides regulatory services to the SEF

pursuant to a Regulatory Services Agreement.

“Reporting Counterparty” has the meaning ascribed to it by CFTC Regulation § 45.1, or any successor regulation

thereto.

“Reporting Party” has the meaning ascribed to it by CFTC Regulation § 43.2, or any successor regulation thereto.

“Review Panel” means the Disciplinary Panel responsible for determining whether a reasonable basis exists for finding

a violation of the SEF Rules, and for authorizing the issuance of notices of charges against Persons alleged to have

committed violations if the Review Panel believes that the matter should be adjudicated.

“SEF” or “the SEF” means Refinitiv US SEF LLC or any successor thereto, a Self-Regulatory Organization registered

with the CFTC as a Swap Execution Facility.

“SEF Activity” means business for which a Participant, Customer, Client or Sponsored Person is subject to the SEF

Rules or which is purportedly conducted subject to the SEF Rules, including but not limited to the Execution of any

Contract on the Platform.

“SEF LLC Agreement” means the Limited Liability Company Agreement of the SEF, originally dated as of March 1,

2013, as the same may be amended from time to time.

“SEF Confirmation” has the meanings attributed to such term in Rule 404(a).

“SEF Official” means any Director or Officer of, or individual employed directly by, the SEF, the Regulatory Services

Provider or any individual rendering similar services to the SEF under an administrative or similar agreement.

“SEF Participant Application” means the User Agreement, onboarding form, and any other agreements or

information that are required to be executed and delivered to the SEF before a Person may access thePlatform.

“SEF Proceeding” and “SEF Proceedings” have the meanings attributed to such terms in Rule 210(a).

“SEF Rules” means all rules adopted, all Notices to Participants published by the SEF, the User Agreement,

interpretations, orders, resolutions, advisories, statements of policy, decisions, manuals and directives of the SEF, and

all amendments thereto.

“Self-Regulatory Action” has the meaning attributed to such term in Rule 210(a).

“Self-Regulatory Organization” shall, unless otherwise provided, have the meaning attributed to such term in CFTC

Regulation § 1.3(ee), or any successor regulation thereto, and, in addition, shall include a Swap Execution Facility,

Contract Market, and registered futures association, such as the NFA.

“Sponsored Access” means the process by which a Participant (“Sponsoring Participant”) provides Trading Privileges

on the SEF to a market participant who is not a Participant (“Sponsored Person”). Sponsored Access takes multiple

forms, including but not limited to: (a) “Sponsored Market Access”, where the Sponsoring Participant provides the

connection to the SEF and the Sponsored Person’s orders pass through the Sponsoring Participant’s systems prior to

reaching the Platform, and (b) “Direct Access”, where the Sponsored Person enters orders directly into the Platform via

its own dedicated connection provided by the SEF under the auspices of and via an arrangement with the Sponsoring

Participant, pursuant to Rule 316.
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“Sponsored Person” shall mean an Eligible Contract Participant which has been provided electronic access to and

Trading Privileges on the SEF by means of a Sponsoring Participant pursuant to Rule 316, and who shall be subject to

the jurisdiction of the SEF and comply with the SEF Rules as if such Sponsored Person was a Participant. For the

avoidance of doubt, all references to Participant other than in Rules 302(a), 305 and 314 shall include Sponsored

Persons and their Authorized Persons.

“Sponsoring Participant” shall mean a Participant that has (i) designated a Sponsored Person to the SEF pursuant to

the SEF Rules and (ii) extended Trading Privileges to such Sponsored Person. Upon acceptance of such designation

by the SEF, the Sponsoring Participant shall be responsible for the obligations provided in Rule 316.

“Swap” or “Swaps” shall have the meaning set forth in Section 1a(47) of the CEA and the CFTC’s rules and regulations

promulgated thereunder.

“Swap Data Repository” shall have the meaning set forth in Section 1a(48) of the CEA and the CFTC’s rules and

regulations promulgated thereunder.

“Swap Dealer” shall have the meaning ascribed to it by CFTC Regulation § 1.3(ggg), or any successor regulation

thereto.

“Swap Execution Facility” shall have the meaning set forth in Section 1a(50) of the CEA and the CFTC’s rules and

regulations promulgated thereunder.

“Swap Execution Facility Addendum” means the addendum to the relevant agreement that Participant has entered

into with a member of the FXall Group or Refinitiv Group which sets forth certain rights and obligations of the Participant

and the SEF.

“Technology Services Agreement” means the agreement(s) between the SEF and the Technology Services Provider

whereby technology services are provided to the SEF.

“Technology Services Provider” means the organization, if any, which provides technology services to the SEF

pursuant to a Technology Services Agreement

“Terms Incorporated by Reference” has the meaning attributed to such term in Rule 404(a).

“Trade Communication” has the meaning attributed to such term in Rule 404(a).

“Trading Hours” means, for any Business Day, the hours during which Orders may be placed on Platform, as shall be

established, and may be revised from time to time, by the SEF pursuant to SEF Rule 903.

“Trading Privileges” means the rights granted to a Participant to transmit Orders for a Contract through the Platform

(including through an ISV).

“Transaction” means any purchase or sale of any Contract made on the Platform or pursuant to the SEF Rules.

“Transaction Data” means, with respect to a Participant, data submitted by that Participant related to requests for

quotes, offers, bids, pricing, matching, netting, settlement and similar data submitted through the Platform to one or

more counterparties, as well as information that such Participant may upload to the Platform with respect to

Transactions conducted otherwise than through the use of the Platform’s functionality, and messages sent in respect

thereof.

“U.S. Person” means a U.S. person as defined in the Commodity Exchange Act and the applicable regulations

promulgated from time to time in connection therewith, or, in each case, under any interpretation or interpretative

guidance issued in connection therewith or successor statute or rule.
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“Unique Product Identifier” means a unique identification of a particular level of the taxonomy of the product in an

asset class or sub-asset class in question, as further described in CFTC Regulation § 43.4(f) and appendix A to CFTC

Regulation Part 45. Such unique product identifier may combine the information from one or more of the data fields

described in such appendix A.

“Unique Swap Identifier” shall have the meaning ascribed to it by CFTC Regulation § 45.5, or any successor

regulation thereto.

“User Agreement” means the relevant agreement that Participant has entered into with a member of the FXall Group

or Refinitiv Group, as amended by the Swap Execution Facility Addendum. For the purposes of the User Agreement

with a member of the FXall Group, any reference to the “System” in the User Agreement shall include theSEF.

“User ID” means a unique user identification number given to each Participant and each Authorized Person to enable

such Participant or Authorized Person to access and use the Platform.

“Valuation Data” has the meaning ascribed to it in CFTC Regulation § 45.1, or any successor regulation thereto.

“Wash Transaction” means a transaction entered into, or purported to be entered into, where the person knows or

reasonably should know that the purpose of the order is to avoid taking a bona fide market position exposed to market

risk.

“written” or “writing” means printing, lithography, photography, and other modes of representing or reproducing words

or data in a visible form, including electronic transmissions.

RULE 102 RULES OF CONSTRUCTION

The following rules of construction shall apply to the SEF Rules:

(a) the headings are for convenience only and do not affect the construction of the SEF Rules;

(b) all references to time are to local time in New York, New York except where expressly provided otherwise;

(c) words denoting a singular number include the plural number where the context permits and vice versa;

(d) where the context permits or requires, any pronoun shall include the corresponding masculine, feminine and

neuter forms;

(e) references to statutory provisions include those provisions as amended from time to time, and any rules or

regulations promulgated thereunder;

(f) references to regulatory rulemakings, including but not limited to the CFTC Regulations, include those

provisions as amended from time to time.
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Chapter 2 – SEF Ownership and Governance

RULE 201 OWNERSHIP

The SEF is a Delaware limited liability company. The management and operation of the SEF is governed by the SEF LLC

Agreement. Refinitiv US LLC owns all of the equity interest in the SEF.

RULE 202 BOARD

(a) The Board shall manage the day to day business operations of the SEF in accordance with the SEF LLC Agreement and

Applicable Law. The Board has the power and authority to call for review, and to affirm, modify, suspend or overrule any and

all decisions and actions of standing committees or special committees of the Board or any panel of the Officers related to the

day to day business operations of the SEF.

(b) The Board may act only by the decision of an absolute majority in number of the Directors, either by vote at a meeting or by

written consent without a meeting, or as otherwise set forth in the SEF LLC Agreement.

(c) Each Director is entitled to indemnification pursuant to the SEF LLC Agreement with respect to matters relating to the SEF or

otherwise relating to Refinitiv US LLC.

(d) Each Director shall satisfy all fitness standards and otherwise meet all the requirements to serving as a director of a Swap

Execution Facility under the CEA and CFTC Regulations.

(e) The compensation of the non-executive members of the Board shall not be linked to the business performance of theSEF.

(f) The Board shall have procedures, as may be further set forth in policies that the SEF may adopt, to remove a member from

the Board where the conduct of such member is likely to be prejudicial to the sound and prudent management of theSEF.

RULE 203 OFFICERS

(a) The Board shall appoint a Chief Executive Officer, a Chief Compliance Officer, and such other officers of the SEF (all of the

foregoing, collectively, the “Officers”) as it may deem necessary or appropriate from time to time, in accordance with the SEF

LLC Agreement.

(b) Any Officer may also be a director, officer, partner or employee of the SEF or any of its Affiliates.

(c) The Officers shall have such powers and duties in the management of the SEF as the Board may prescribe from time to time.

(d) Each Director and Officer is entitled to indemnification pursuant to the SEF LLC Agreement with respect to matters relating to

the SEF or otherwise relating to Refinitiv (Markets) LLC.

RULE 204 QUALIFICATIONS OF DIRECTORS, DISCIPLINARY PANEL MEMBERS, COMMITTEE MEMBERS

AND OFFICERS

(a) A Director or Officer must meet the qualifications set forth from time to time in the SEF LLC Agreement.

(b) An individual may not serve as a Director, or serve on a committee established by the Board or a Disciplinary Panel if the

individual:

(1) within the prior three (3) years has been found, by a final decision in any action or proceeding brought in a court of

competent jurisdiction, the CFTC, or any Self-Regulatory Organization, to have committed a disciplinary offense;

(2) within the prior three (3) years has entered into a settlement agreement in which any of the findings or, in the
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absence of such findings, any of the acts charged, included a disciplinary offense;

(3) is currently suspended from trading on a Contract Market, is suspended or expelled from membership in a SelfRegulatory Organization, is serving any sentence or probation, or owes any portion of a fine or penalty related to

either:

i. a finding of a disciplinary offense by a final decision in any action or proceeding brought in a court of

competent jurisdiction, the CFTC, or any Self-Regulatory Organization; or

ii. a settlement agreement in which any of the findings or, in the absence of such findings, any of the acts

charged included a disciplinary offense;

(4) is currently subject to an agreement with the CFTC or Self-Regulatory Organization not to apply for registration with

the CFTC or for membership in the Self-Regulatory Organization;

(5) is currently, or within the past three (3) years has been, subject to a revocation or suspension of registration by the

CFTC;

(6) has been convicted of a felony listed in section 8a(2)(D)(ii) through (iv) of the CEA; or

(7) is currently subject to a denial, suspension or disqualification from serving on a disciplinary committee, arbitration

panel or governing board of any self-regulatory organization as that term is defined in section 3(a)(26) of the

Securities Exchange Act of 1934.

(c) Any Director, Officer, member of a committee established by the Board, any member of a Disciplinary Panel, any individual

nominated to serve in any such role, or any individual authorized by a Hearing Panel to take summary action shall

immediately notify the Chief Executive Officer if such individual meets one or more of the criteria in Rule 204(b).

(d) For purposes of Rule 204(b), the terms “disciplinary offense,” “final decision,” and “settlement agreement” have the meanings

set forth in CFTC Regulation § 1.63(a) or any successor regulation.

RULE 205 CHIEF COMPLIANCE OFFICER

(a) The Chief Compliance Officer shall have the following duties:

(1) Overseeing and reviewing the SEF’s compliance with Section 5h of the CEA and any related rules

adopted by the CFTC;

(2) In consultation with the Board, resolving any conflicts of interest that may arise including:

i. Conflicts between business considerations and compliance requirements;

ii. Conflicts between business considerations and the requirement that the SEF provide fair, open,

and impartial access as set forth in CFTC Regulation § 37.202 or any successor regulation; and;

iii. Conflicts between the SEF’s management and members of the Board;

(3) Establishing and administering written policies and procedures reasonably designed to prevent violation of

the CEA and any rules adopted by the CFTC;

(4) Taking reasonable steps to ensure compliance with the CEA and CFTC regulations;

(5) Establishing procedures for the remediation of noncompliance issues identified by the Chief Compliance

Officer through a compliance office review, look-back, internal or external audit finding, self-reported

error, or validated complaint;
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(6) Establishing and following appropriate procedures for the handling, management response, remediation,

retesting, and closing of noncompliance issues;

(7) Establishing and administering a compliance manual designed to promote compliance with the applicable

laws, rules, and regulations and a written code of ethics designed to prevent ethical violations and to

promote honesty and ethical conduct;

(8) Supervising the SEF’s self-regulatory program with respect to trade practice surveillance; market

surveillance; real-time market monitoring; compliance with audit trail requirements; enforcement and

disciplinary proceedings; audits, examinations, and other regulatory responsibilities with respect to

Participants, Customers and Clients (including ensuring compliance with, if applicable, financial integrity,

financial reporting, sales practice, recordkeeping, and other requirements); and

(9) Supervising the effectiveness and sufficiency of any regulatory services provided to the SEF by the

Regulatory Services Provider or other Registered Entity in accordance with CFTC Regulation § 37.204 or

any successor regulation.

(b) The Chief Compliance Officer shall have the authority and resources to develop and enforce policies and procedures

necessary to fulfill the duties set forth herein as well as set forth in the CEA and CFTC regulations.

(c) The Chief Compliance Officer shall report directly to the Board. The Chief Compliance Officer shall meet with the Board at

least annually and shall meet with the Regulatory Oversight Committee at least quarterly. The Chief Compliance Officer shall

provide any information regarding the regulatory program of the SEF operated by the SEF that is requested by the Board or

the Regulatory Oversight Committee.

(d) The Board shall approve the compensation of the Chief Compliance Officer.

(e) The Chief Compliance Officer shall have the authority to inspect the books and records of all Participants and the authority to

require any Participant to appear before him or her and produce its books and records and answer questions regarding

alleged violations of the SEF Rules, at the time, place and in the manner it designates. The Regulatory Services Provider may

also perform these functions on behalf of the Chief Compliance Officer.

(f) The Chief Compliance Officer may not be disqualified from registration pursuant to Sections 8a(2) or 8a(3) of the CEA.

(g) The Chief Compliance Officer shall annually prepare and sign a report pursuant to the requirements in Section 37.1501(e)

and 37.1501(f) which shall contain:

(1) A description of the SEF's written policies and procedures, including the code of ethics and conflict of

interest policies;

(2) A review of applicable CFTC Regulations and each subsection and core principle of section 5h of the

CEA, that, with respect to each:

i. Identifies the policies and procedures that are designed to ensure compliance with each

subsection and core principle, including each duty specified in section 5h(f)(15)(B) of the CEA;

ii. Provides a self-assessment as to the effectiveness of these policies and procedures; and;

iii. Discusses areas for improvement and recommends potential or prospective changes or

improvements to its compliance program and resources;

(3) A list of any material changes to compliance policies and procedures since the last annual compliance

report;
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(4) A description of the financial, managerial, and operational resources set aside for compliance with respect

to the CEA and CFTC Regulations, including a description of the SEF’s self-regulatory program's staffing

and structure, a catalogue of investigations and disciplinary actions taken since the last annual compliance

report, and a review of the performance of disciplinary committees and panels;

(5) A description of any material compliance matters, including noncompliance issues identified through a

compliance office review, look-back, internal or external audit finding, self-reported error, or validated

complaint, and an explanation of how they were resolved;

(6) A certification by the Chief Compliance Officer that, to the best of his or her knowledge and reasonable

belief, and under penalty of law, the annual compliance report is accurate and complete.

(h) Removal of the Chief Compliance Officer shall require the approval of a majority of the SEF’s Board.

(i) If the Chief Compliance Officer is removed from his or her post, the SEF shall notify the CFTC of the removal within two

business days.

RULE 206 STANDING COMMITTEES

(a) The Board shall initially have one standing committee: the Regulatory Oversight Committee. The Board may from time to time

constitute and appoint in accordance with the SEF LLC Agreement such additional standing committees of the Board as it

may from time to time deem necessary or advisable.

(b) Each member of such standing committees must be a Director, one of whom the Board shall designate as the chairperson of

each standing committee.

(c) Each standing committee shall assist in the supervision, management and control of the affairs of the SEF within its particular

area of responsibility, subject to the authority of the Board.

(d) Subject to the authority of the Board, each standing committee shall determine the manner and form in which its proceedings

shall be conducted. Each standing committee may act only by the decision of an absolute majority in number of the members

of such committee, by vote at a meeting or by unanimous written consent without a meeting. The Board has the authority to

overrule the decisions of a standing committee.

RULE 207 REGULATORY OVERSIGHT COMMITTEE

(a) The Regulatory Oversight Committee of the Board shall consist of at least two Directors appointed from time to time by the

Board. In the event of a tie between the two Directors, the Chief Compliance Officer may vote on any matter for which she/he

does not have a potential or actual conflict of interest.

(b) Each member of the Regulatory Oversight Committee shall serve for a term of two calendar years from the date of their

appointment or for the remainder of their term as a Director, and until the due appointment of his or her successor, or until his

or her earlier resignation or removal, with or without cause, as a member of the Regulatory Oversight Committee or as a

Director. A member of the Regulatory Oversight Committee may serve for multiple terms.

(c) The Regulatory Oversight Committee shall oversee the SEF’s regulatory program on behalf of the Board. The Board shall

delegate sufficient authority, dedicate sufficient resources, and allow sufficient time for the Regulatory Oversight Committee to

fulfill its mandate. It shall make such recommendations to the Board as will, in its judgment; best promote the interests of the

SEF. The Regulatory Oversight Committee shall also have such other powers and perform such other duties as set forth in

the SEF Rules and as the Board may delegate to it from time to time.

(d) Without limiting the generality of the foregoing, the Regulatory Oversight Committee shall have authority to:

(1) Monitor the regulatory program of the SEF for sufficiency, effectiveness, and independence;

(2) Oversee all facets of the regulatory program, including:
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i. Trade practice and market surveillance; audits, examinations, and other regulatory responsibilities with

respect to Participants (including compliance with, if applicable, financial integrity, financial reporting, sales

practice, recordkeeping, and other requirements); and the conduct of investigations;

ii. Reviewing the size and allocation of the regulatory budget and resources, and the number, hiring,

termination, and compensation of regulatory personnel;

iii. Reviewing the performance of the Chief Compliance Officer and making recommendations with respect to

such performance to the Board;

iv. Recommending changes that would ensure fair, vigorous, and effective regulation; and

v. Reviewing all regulatory proposals prior to implementation and advising the Board as to whether and how

such changes may impact regulation.

(e) The Regulatory Oversight Committee reports to the Board.

RULE 208 ADDITIONAL BOARD COMMITTEES AND SEF PANELS

(a) In addition to the standing committees described in Rule 206, the Board may from time to time constitute and appoint, in

accordance with the SEF LLC Agreement, special committees of the Board and designate their composition, responsibilities

and powers. Each member of such special committees must be a Director.

(b) The SEF may create panels of the SEF, for such purposes as may from time to time be necessary or advisable. Members of

each such panel may be Directors or Participants (if individuals) or any of a Participant’s Authorized Persons (if an entity) or

such other individuals as may be qualified to serve on such panel.

(c) Except as otherwise specifically provided in the SEF Rules, the members of any additional committee or panel shall be

appointed as determined by the Board. The Board shall designate the chairperson of such additional committee or panel.

(d) Each additional committee or panel shall assist in the supervision, management and control of the affairs of the SEF within its

particular area of responsibility.

(e) Subject to the authority of the Board, each additional committee or panel shall determine the manner and form in which its

proceedings shall be conducted. Each additional committee or panel may act only by the decision of an absolute majority in

number of the members of such committee or panel, either by vote at a meeting or by unanimous written consent without a

meeting.

RULE 209 EMERGENCY RULES

(a) During an Emergency, the SEF may implement Emergency Rules, subject to the applicable provisions of the CEA and CFTC

Regulations. Pursuant to the Emergency Rules, the SEF will have the authority to intervene as necessary to maintain markets

with fair and orderly trading and to prevent or address manipulation or disruptive trading practices, whether the need for

intervention arises exclusively from the SEF’s market or as part of a coordinated, cross-market intervention.

Emergency Rules may require or authorize the SEF, the Board, any committee of the Board, the Chief Executive Officer, the

Chief Compliance Officer, or any other Officer to take actions necessary or appropriate to respond to the Emergency,

including, but not limited to, the following actions:

(1) imposing or modifying position limits,

(2) imposing or modifying price limits;

(3) imposing or modifying intraday market restrictions;

(4) imposing special margin requirements, including working with a Derivatives Clearing Organization to impose

special margin requirements;

(5) ordering the liquidation or transfer of open positions in any Contract;

(6) ordering the fixing of a settlement price;

(7) extending or shortening the expiration date or the Trading Hours;

(8) suspending or curtailing trading in any Contract;
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(9) transferring customer Contracts and the margin, or altering any Contract’s settlement terms or conditions;

(10) if applicable, providing for the carrying out of such actions through its agreements with the Regulatory Services

Provider; or

(11) taking market actions as may be directed by the CFTC.

(b) Before any Emergency Rule may be adopted and enforced, a required vote of the Regulatory Oversight Committee must

approve the enforcement of such Emergency Rule at a duly convened meeting. Directors may attend such a meeting by

teleconference. If the Chief Executive Officer or Chief Compliance Officer determines that Emergency Rules must be

implemented with respect to an Emergency before a meeting of the Regulatory Oversight Committee can reasonably be

convened, then the Chief Executive Officer or Chief Compliance Officer shall have the authority, without Board or Committee

action, to implement any Emergency Rules with respect to such Emergency that he or she deems necessary or appropriate to

respond to such Emergency. In such circumstances, the Chief Executive Officer or Chief Compliance Officer must convene a

meeting as soon as practicable.

(c) Whenever the SEF, the Board, any committee of the Board, the Chief Executive Officer or Chief Compliance Officer takes

actions necessary or appropriate to respond to an Emergency, a duly authorized person of the SEF, where possible, will post

an announcement in a Notice to Participants. When the Board, any committee of the Board, the Chief Executive Officer or the

Chief Compliance Officer determines that the Emergency has been reduced sufficiently to allow the SEF to resume normal

functioning, any such actions responding to an Emergency will be terminated.

(d) In situations where a Swap is traded on more than one Swap Execution Facility, emergency action to liquidate or transfer

open interest must be directed, or agreed to, by the CFTC or CFTC staff, and the SEF will use reasonable efforts to

coordinate with any Derivatives Clearing Organization that has cleared the Swap and any other Swap Execution Facilities

where such Swap is traded prior to mandating the liquidation or transfer of such Swap.

(e) The SEF will use reasonable efforts to notify the CFTC prior to implementing, modifying or terminating an Emergency Rule. If

such prior notification is not possible or practicable, the SEF will notify the CFTC at the earliest possible time after

implementation, modification or termination, but in no event more than twenty-four hours after implementation, modification or

termination.

(f) Upon taking any action in response to an Emergency, the SEF will document the decision- making process and the reasons

for taking such action. Information on any regulatory action taken pursuant to the Emergency Rules will be included in a

submission of a certified rule to the CFTC. All such documentation will be kept for at least five years, two years in a readily

accessible location, following the date on which the Emergency ceases to exist or to affect the SEF, and all such

documentation will be provided to the CFTC upon request.

(g) Upon taking any action in response to an Emergency, the SEF will promptly notify the CFTC of the SEF’s exercise of the

Emergency Rules, explaining its decision-making process, the reasons for using its emergency authority, and how conflicts of

interest were minimized, including the extent to which the SEF considered the effect of its emergency action on the underlying

markets and on markets that are linked or referenced to the contracts traded on its facility, including similar markets on other

trading venues.

RULE 210 CONFLICTS OF INTEREST AND MISUSE OF MATERIAL, NON-PUBLIC INFORMATION

(a) A Director, Officer, Disciplinary Panel member or other Person authorized to exercise the SEF’s authority concerning any

inquiry, investigation, disciplinary proceeding, summary suspension, or other summary actions (any such action, a “SEF

Proceeding” and, collectively, “SEF Proceedings”), or Emergency actions taken pursuant to Rule 209 or emergency

disciplinary action taken pursuant to Rule 1014 (each such SEF Proceeding or Emergency action, a “Self-Regulatory

Action”) who knowingly has a “material conflict of interest” between his or her position as a Director, Officer, panel member or

exercise of authority concerning a Self-Regulatory Action and his or her personal interests (each, an “Interested Person”)

may not participate in any deliberations or vote of the Board Committee, panel or exercise any authority with respect to such

Self-Regulatory Action involving his or her personal interest, except as described in Rule 210(d).

(b) For purposes of Rule 210(a), a “material conflict of interest” means a Director, Officer, Disciplinary Panel Member or other

Person:

(1) being named as a respondent or potential respondent in the Self-Regulatory Action;
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(2) being an employer, employee, fellow employee or an Affiliate of a respondent or potential respondent in the SelfRegulatory Action;

(3) having any significant, ongoing business relationship with a respondent or potential respondent in the

Self-Regulatory Action;

(4) having a family relationship with a respondent or potential respondent in a Self-Regulatory Action (including the

individual’s spouse, co-habitator, former spouse, parent, step-parent, child, step-child, sibling, step-brother, stepsister, grandparent, grandchild, uncle, aunt, nephew, niece, father-in-law, mother-in-law, brother-in-law or sister-inlaw);

(5) having a direct and substantial financial interest in the result of the deliberations or vote based upon either exchange

or non-exchange positions (as referenced in Section 1.69 of the CFTC Regulations), other than a direct or indirect

equity or other interest in Refinitiv US LLC, that could reasonably be expected to be affected by the action. A direct

and substantial financial interest includes positions in Contracts in accounts of, controlled by, or affiliated with the

Interested Person or in any other types of direct and substantial financial positions of the Interested Person that are

reasonably expected to be affected by the deliberations or vote; and/or

(6) any other circumstance that gives rise to a conflict between the Director’s, Officer’s, Disciplinary Panel Member’s or

Other Person’s exercise of authority concerning any Self-Regulatory Action and his or her personal interests.

(c) Before considering any Self-Regulatory Action, an Interested Person must disclose in writing to the Board the material facts

concerning his or her relationship or interest in the matter.

(d) Any Interested Person who would be required otherwise to abstain from deliberations and voting pursuant to Rule 210(a) as a

result of having a direct and substantial financial interest in the result of the deliberations and vote may participate in

deliberations, but shall not vote on the matter, if:

(1) the material facts about the Interested Person’s financial interest in the matter are disclosed or known to the Board,

Committee, or Disciplinary Panel;

(2) the Board, Committee, or Disciplinary Panel determines that the participation by the Interested Person would be

consistent with the public interest; and

(3) a majority of the Directors (excluding any Interested Persons) vote to allow the Interested Person to participate in

deliberations on the matter.

(e) If a determination is made pursuant to Rule 210(d) that an Interested Person may participate in deliberations prior to a vote,

then the minutes of the meeting of the Board or committee thereof will reflect the determination and the reasons for the

determination.

(f) If a determination is made that all Directors are Interested Persons with respect to a matter subject to a vote by the Board, the

Chief Executive Officer will appoint a panel of individuals who are not Interested Persons with respect to such matter, which

will have the same authority and powers over such matter that the Board would have if the Directors were not Interested

Persons with respect to such matter.

(g) No Director, Officer or member of any committee or panel established by the Board shall use or disclose for any purpose

other than the performance of his or her official duties and responsibilities as a Director, Officer or committee or panel

member any material, non-public information obtained as a result of the individual’s duties and responsibilities as a Director,

Officer or committee or panel member. No Director, Officer or committee or panel member shall, directly or indirectly, disclose

or use at any time, either during his or her association with the SEF or thereafter, any confidential information of which the

Board member or committee or panel member becomes aware. Each Director, Officer or committee or panel member in

possession of confidential information shall take all appropriate steps to safeguard the information and to protect it against

disclosure, misuse, espionage, loss and theft.

(h) Notwithstanding Rule 210(g), a Director, Officer or committee or panel member may disclose confidential information if

required by Applicable Law or a court order to be revealed to the United States Department of Justice or the CFTC.
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(i) For the purposes of Rule 210(g), the terms “material information” and “non-public information” shall each have the meaning

set forth in CFTC Regulation § 1.59(a) or any successor regulation.

RULE 211 INFORMATION-SHARING AGREEMENTS

(a) The SEF may enter into information-sharing agreements or other arrangements or procedures to coordinate surveillance with

other markets on which financial instruments related to the Contracts trade, and such international information-sharing

agreements as the CFTC may require. As part of any information-sharing agreements or other arrangements or procedures

adopted pursuant to this Rule, the SEF may:

(1) provide market surveillance reports to the CFTC, any Government Agency with jurisdiction over the SEF or, as

necessary for the SEF to comply with its SRO obligations, to other markets;

(2) share information and documents concerning current and former Participants with the CFTC, any Government

Agency with jurisdiction over the SEF or, as necessary for the SEF to comply with its SRO obligations, to other

markets;

(3) share information and documents concerning ongoing and completed investigations with the CFTC, any Government

Agency with jurisdiction over the SEF or, as necessary for the SEF to comply with its SRO obligations to other

markets; and/or

(4) require its current or former Participants to provide information and documents to the SEF at the request of the

CFTC, any Government Agency with jurisdiction over the SEF or, as necessary for the SEF to comply with its SRO

obligations, other markets.

(b) The SEF may enter into any information sharing arrangement with any Person or body (including, without limitation, the

CFTC, the NFA, any Self-Regulatory Organization, any exchange, market, or Derivatives Clearing Organization, or foreign

regulatory authority) if the SEF considers such arrangement to be in furtherance of the SEF’s purpose or duties under the

SEF Rules or any law or regulation.

(c) The SEF may disclose to any Person or entity information concerning or associated with a Participant or other Person that the

SEF believes is necessary and appropriate in exercising a legal or regulatory function, whether or not a formal arrangement

governing the disclosure exists or a request for information was made.

RULE 212 SERVICES AGREEMENT WITH A REGULATORY SERVICES PROVIDER

(a) The SEF may choose to contract with a Regulatory Services Provider, for the provision of services to assist in complying

with the core principles, as approved by the Commission. If the SEF chooses to contract with a Regulatory Services

Provider, it will ensure that the Regulatory Services Provider has the capacity and resources necessary to provide timely and

effective regulatory services, including adequate staff and automated surveillance systems.

(b) If the SEF chooses to contract with a Regulatory Services Provider, the SEF will at all times remain responsible for the

performance of any regulatory services received, for compliance with the SEF’s obligations under the CEA and Commission

regulations, and for the Regulatory Services Provider’s performance on its behalf.

(c) If the SEF chooses to contract with a Regulatory Services Provider, the SEF will retain exclusive authority in all substantive

decisions made by its Regulatory Services Provider, including but not limited to decisions involving the cancellation of

trades, the issuance of disciplinary charges against Participants or market participants, and denials of access to the trading

platform for disciplinary reasons. The SEF shall document any instances where its actions differ from those recommended

by its Regulatory Services Provider, including the reasons for the course of action recommended by the Regulatory Service

Provider and the reasons why the SEF chose a different course of action.

RULE 213 SERVICES AGREEMENT WITH A TECHNOLOGY SERVICES PROVIDER

(a) The SEF may contract with a Technology Services Provider to provide certain technology services to the SEF pursuant to a

Technology Services Agreement. In accordance with a Technology Services Agreement, a Technology Services Provider

may perform certain functions under the SEF Rules and the SEF may provide information to the Technology Services

Provider in connection with the performance by the Technology Services Provider of those functions.
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(b) The SEF shall retain ultimate decision-making authority with respect to any functions that are contracted to a Technology

Services Provider.

Chapter 3 – Participants

RULE 301 CRITERIA FOR BECOMING A PARTICIPANT

(a) To be eligible for admission as a Participant of the SEF, an applicant must demonstrate to the satisfaction of the SEF that it:

(1) is an Eligible Contract Participant (which may be demonstrated through a representation);

(2) is of good reputation and business integrity;

(3) maintains adequate financial resources and credit;

(4) is of the age of majority in the individual’s state of residence (if an individual);

(5) is validly organized, in good standing, and authorized by its governing body and, if relevant, documents of

organization, to trade Contracts (if an entity);

(6) has not filed for bankruptcy;

(7) is not prohibited from using the services of the SEF for any reason whatsoever;

(8) holds all registrations required under Applicable Law, including any Swap Dealer, Major Swap Participant,

Introducing Broker, Futures Commission Merchant, commodity pool operator, commodity trading advisor, associated

person registration, as applicable;

(9) is not subject to statutory disqualification under Section 8a(2) of the CEA;

(10) consents to the SEF’s jurisdiction pursuant to Rule 311; and

(11) satisfies any other criteria that the SEF may require from a Participant.

If a Participant’s status as an Eligible Contract Participant changes, such Participant must immediately notify the SEF of such

change.

(b) No Participant, including a Participant that is an Account Manager or a Sponsoring Participant, shall carry an account for a

Customer, enter an Order in the name of or on behalf of a Client or extend Trading Privileges to a Sponsored Person unless

the Participant has entered into a written Intermediary Agreement with such Customer, Client or Sponsored Person, that is in

compliance with Applicable Law and the SEF Rules and Obligations.

(c) Each Participant must: (1) ensure that the Customer, Client or Sponsored Person is an Eligible Contract Participant at the

time of execution of any Swap; (2) subject every Swap executed for the Customer, Client or Sponsored Person to the SEF

Rules and Obligations insofar as they are applicable to that Swap; (3) in relation to any Swap executed for the Customer,

Client or Sponsored Person, be able to comply with all requirements of the SEF Rules and Obligations and any other

arrangements, provisions and directions given by the SEF; and (4) provide the SEF and its agents, including the Regulatory

Services Provider, access to all information and staff in connection with or related to its SEF Activity necessary for monitoring

and enforcement of the SEF Rules and Obligations.

(d) Once admitted, the Participant shall continue to comply with all applicable eligibility criteria in Rule 301(a).

(e) [Reserved]

(f) [Reserved]
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(g) [Reserved]

(h) [Reserved]

(i) [Reserved]

(j) The SEF may allow, deny, suspend, or permanently bar a Participant’s access to the Platform pursuant to disciplinary

measures or emergency action, or for any other reason at the sole discretion of the SEF or its Regulatory Service Provider,

provided that any decision to allow, deny, suspend, or permanently bar a Participant’s access to the Platform shall be

impartially enforced.

RULE 302 PARTICIPANT APPLICATION PROCESS

(a) Any Person who desires to become a Participant shall:

(1) enter into a User Agreement or Swap Execution Facility Addendum;

(2) [Reserved]

(3) [Reserved]

(4) agree to abide by the SEF Rules and Applicable Law;

(5) provide such information and documentation as may be requested by the SEF pertaining to the Participant or the

Participant’s Clients if Participant is an Account Manager, and follow the procedures established by the SEF for

admission; and,

(6) if Participant is organized or located outside of the United States, enter into a written agreement acceptable to the

SEF appointing a third party as its U.S. agent for service of process for purposes of CFTC Regulation 15.05, and

shall provide the SEF with a copy of the agreement.

(b) In considering an application from a potential Participant, the SEF may require additional information from the applicant, or

conduct an investigation to verify information submitted by the applicant, or both.

(c) In determining whether to admit an applicant as a Participant, the SEF will evaluate, among other things, the applicant’s

disciplinary history and financial and operational soundness.

(d) If the SEF decides to admit an applicant as a Participant, it shall promptly notify the applicant and state in such notice the date

on which the applicant shall become a Participant.

(e) The SEF may deny, condition or terminate Participant status of any Person:

(1) If such Person is unable to satisfactorily demonstrate its ability to satisfy the eligibility criteria to become or remain a

Participant;

(2) If such Person is unable to satisfactorily demonstrate its capacity to adhere to all applicable SEF Rules;

(3) If such Person would bring the SEF into disrepute as determined by the SEF in its sole discretion; or,

(4) for such other cause as the SEF may reasonably determine

provided that any decision to deny, condition or terminate the Participant status of any Person shall be impartially enforced.

(f) If the SEF has a Regulatory Service Provider pursuant to Rule 212, the SEF shall nonetheless retain exclusive authority over

decisions to deny access to the SEF.

(g) If the SEF decides to decline or condition an application for admission as a Participant, or terminate a Person’s status as a
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Participant, the SEF shall promptly notify such Person (the “Affected Person”) thereof in a writing sent to the address

provided by the applicant in the SEF Participant Application form or maintained in the SEF registry of Participants. Such

Affected Person may, within seven (7) calendar days, request in writing that the SEF provide the reasons for the denial,

conditioning or termination of Participant status. Within fourteen (14) calendar days after receiving such written request, the

SEF shall send a written response to the Affected Person setting forth the reasons for the denial, conditioning or termination.

Within fourteen (14) calendar days of receiving the SEF’s written response, the Affected Person may request in writing that

the Board reconsider the determination.

(h) Within twenty-eight (28) calendar days of receiving any request for reconsideration, the Board shall either confirm, reverse or

modify the denial, conditioning or termination of the Affected Person as a Participant, and shall promptly notify the Affected

Person accordingly in writing. The Board may, within its discretion, schedule a hearing (in-person or by teleconference);

request additional information from the Affected Person; or, establish any other process that it believes is necessary and

appropriate to consider the request for reconsideration.

(i) The Board’s decision is the final action of the SEF and is not subject to appeal within the SEF.

(j) Access to the SEF by an ISV shall be provided in a fair and nondiscriminatory manner, but a Person seeking to act as an ISV

must:

(1) execute the ISV Agreement,

(2) satisfy the SEF’s technological integrity requirements and not adversely affect the SEF’s ability to comply with the

CEA and CFTC Regulations,

(3) agree to the terms of the ISV Agreement (including all applicable annexes and exhibits), the SEF Rules and any and

all other documents referenced in the ISV Agreement, and

(4) provide all information that may be reasonably requested from time to time by the SEF.

(k) Persons seeking access to the Platform via an ISV must themselves be Participants or Clients or Customers of a Participant.

RULE 303 TRADING PRIVILEGES

(a) A Participant must execute such Participant Documentation as required from time to time by the SEF, and such Participant

Documentation must remain in effect for the Participant to maintain its Trading Privileges.

(b) Admission as a Participant only entitles the Participant to the Trading Privileges and does not confer any right of ownership in,

or right to attend or vote at meetings of, the SEF, or right to share in the profits, of the SEF. A Participant may not transfer or

assign its status as a Participant without the prior written consent of the SEF, and any purported transfer or assignment

without the SEF’s prior consent is not binding on the SEF.

(c) Any Person that has been granted Trading Privileges, including a Sponsored Person, is a member of the SEF for purposes of

the CEA.

RULE 304 ACCESS TO THE PLATFORM

(a) The SEF may at any time revoke, suspend, limit, condition, restrict or qualify a Participant’s or Sponsored Person’s Trading

Privileges and/or ability to access the Platform, if in the sole discretion of the SEF or its Regulatory Service Provider, such

action is in the best interests of the SEF, provided that any decision to revoke, suspend, limit, condition, restrict or qualify a

Participant’s or Sponsored Person’s Trading Privileges and/or ability to access the Platform shall be impartially enforced.

(b) [Reserved]

RULE 305 DUES, ASSESSMENTS AND FEES

(a) The SEF shall have the authority to set the amounts and times of payment for any dues, assessments or fees to be paid by

Participants. These dues, assessments or fees may include, but not be limited to, the Platform fees, clearing fees, brokerage

fees, transaction surcharges, and the fees described in Rules 401(a)(5) and 402(a)(7).
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(b) Each Participant agrees to pay such dues, assessments, and fees as are published by the SEF from time to time. Each

Participant agrees to pay such dues, assessments, and fees when due.

(c) If a Participant fails to pay when due any such dues, assessments or fees levied on such Participant, and such payment

obligation remains unsatisfied for thirty (30) days after its due date, the SEF may suspend, revoke, limit, condition, restrict or

qualify the Participant’s Trading Privileges and/or ability to otherwise access the Platform as it deems necessary or

appropriate.

(d) The SEF may modify or amend such dues, assessments, or fees as are published by the SEF through a Notice to

Participants as described in Rule 309, and any such amendment shall be applicable to and binding on the Participant and

shall be effective twenty-five (25) calendar days after the later of the date that it is posted on the SEF website and is

transmitted to Participants; provided, however, that notwithstanding any provision in the User Agreement, a Participant may

terminate its membership in the SEF by providing written notice to the SEF that it objects to a modification or amendment of

the SEF’s dues, assessments or fees within thirty (30) calendar days of the effective date of any such modification or

amendment. Any termination under this Rule 305(d) will become effective fifteen (15) calendar days after such written notice

is received by the SEF. Any Participant that terminates its membership under this Rule 305(d) shall remain responsible for

any dues, assessments, fees and Obligations applicable to any Transactions effected or activity conducted prior to any such

termination, and Rule 931 shall survive any such termination.

RULE 306 PARTICIPANT REPRESENTATIVES

Rule 306.A Authorized Persons

(a) Each Participant who is not a natural person shall designate an Authorized Person(s) by listing such Authorized Persons on

the SEF Participant Application or by otherwise providing the SEF with the information requested in the SEF Participant

Application related to Authorized Persons. Participant must designate an Authorized Person prior to permitting such

Authorized Person to access the Platform and agrees to notify the SEF of any change in its AuthorizedPersons.

(b) Any person who is an Authorized Person must: (i) utilize the Participant’s Legal Entity Identifier or CICI for all activities on the

Platform; and (ii) utilize the User ID provided by the SEF to such Authorized Person.

Rule 306.B Authorized Representatives

(a) Authorized Representatives will represent the Participant before the SEF and its committees and receive notices

on behalf of such Participant.

(b) Authorized Representatives shall be empowered by the Participant to act on its behalf, and the SEF shall be

entitled to rely on the actions of Authorized Representatives as binding on the Participant, unless and until

Participant has notified the SEF that such Authorized Representative's designation has been revoked

(c) Each Participant must provide the SEF with current contact and other requested information for each of its

Authorized Representatives so that the SEF is able to immediately contact such AuthorizedRepresentatives.

RULE 307 IDENTIFICATION OF AUTHORIZED PERSONS

(a) Each person trading on behalf of a Participant or a Sponsored Person shall be identified to the SEF by Participant’s or

Sponsored Person’s Legal Entity Identifier and shall be subject to the SEF Rules. It is the duty of the Participant and

Sponsored Person to ensure that Legal Entity Identifiers or CICIs are current and accurate at all times. Participant and

Sponsored Persons shall not use, and the SEF may deny Participant access to, the Platform at any time that Participant has,

or is required by CFTC regulations to have, a Legal Entity Identifier or CICI if Participant does not have such a Legal Entity

Identifier or CICI, as the case may be, or has not notified the SEF in writing of such Legal Entity Identifier or CICI.

(b) Each Participant and each Authorized Person will also individually receive a User ID and a corresponding password to enable

such Participant or Authorized Person to access and use the Platform. Each individual must use a Legal Entity Identifier or
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CICI and User ID to access the Platform. In no event may a Person enter an Order or permit the entry of an Order by an

individual using User ID other than the individual’s own User ID.

(c) Upon becoming aware of any improper access to or use of the Platform, Participant shall immediately notify the SEF and shall

immediately terminate such Person’s access to and use of the Platform. Participant shall be responsible for, and shall take

and maintain appropriate steps to ensure, the security of Participant’s (and Participant’s Authorized Persons’) use of the

Platform.

RULE 308 RECORDING OF COMMUNICATIONS

The SEF or the Regulatory Services Provider may record conversations and retain copies of electronic communications between

SEF Officials, on one hand, and Participants and their Authorized Persons, on the other hand. Any such recordings may be

retained by the SEF or the Regulatory Services Provider in such manner and for such periods of time as the SEF may deem

necessary or appropriate. The SEF or Regulatory Services Provider will retain such recording in compliance with CFTC

Regulations. The Regulatory Services Provider will have access to such recordings to the extent required to perform certain

regulatory services to the SEF pursuant to the Regulatory Services Agreement. Participants hereby consent to such recordings.

RULE 309 NOTICES TO PARTICIPANTS

(a) The SEF shall publish and transmit a Notice to Participants with respect to each addition to, modification of, or clarification of,

the SEF Rules or of any action to implement any of the SEF Rules. A Notice to Participants shall be posted on the SEF’s

website and transmitted to Participants via an electronic mail distribution or through any other electronic or digital

communications system not prohibited by Applicable Law in order to enable each Participant 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.

(b) Any Notice to Participants published and transmitted in accordance with Rule 309(a) shall also be deemed to have been

made to all Account Managers, Clients, Customers, Sponsored Persons, Authorized Representatives and Authorized

Persons.

RULE 310 COMMUNICATIONS BETWEEN THE SEF AND PARTICIPANTS

(a) Each Participant must provide the SEF with its current electronic mail address and telephone number and the electronic mail

address and telephone number of any of its Authorized Persons, and immediately (and in any event within 24 hours) update

this information whenever it changes.

(b) All communications made to Participants shall also be deemed to have been made to all Authorized Representatives and

Authorized Persons, and all communications made to an Authorized Representative or Authorized Person shall also be

deemed to have been made to Participant.

RULE 311 APPLICATION OF THE SEF RULES AND JURISDICTION

(a) By becoming a Participant, accessing the Platform or entering any Order or submitting any Contract into the Platform, whether

directly or through an intermediary, and without any need for any further action, undertaking or agreement, a Participant and

its Authorized Person(s), and the Clients and Customers of any Participant, and any Sponsored Person, any ISVagree:

(1) to be bound by, and comply with, the SEF Rules and obligations and Applicable Law, in each case to the extent

applicable to it;

(2) to become subject to the jurisdiction of the SEF with respect to any and all matters arising from, related to, or in

connection with, the status, actions or omissions of such Person;

(3) to permit the SEF and any Regulatory Services Provider authorized to act on behalf of the SEF to access any and all

information relevant to activities related to the SEF business;

(4) to assist the SEF in complying with its legal and regulatory obligations, cooperate with the SEF and the CFTC in any

inquiry, investigation, audit, examination or proceeding; and
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(5) that the SEF is authorized to provide information regarding such Person to the Regulatory Services Provider, the

CFTC or any Self-Regulatory Organization.

(b) Any Participant, its Authorized Person(s), and the Clients and Customers of any Participant, or any ISV whose Trading

Privileges and/or ability otherwise to access the Platform are revoked or terminated shall remain bound by the SEF Rules and

Applicable Law, in each case to the extent applicable to it, and subject to the jurisdiction of the SEF with respect to any and all

matters arising from, related to, or in connection with, the status, actions or omissions of such Person prior to such revocation

or termination.

RULE 312 DESCRIPTION OF PARTICIPANT’S STATUS

A Participant shall ensure that the form, content and context of any description of the Participant’s status on the SEF to Customers

is not inconsistent with, and does not misrepresent, the Participant’s capacity on the SEF under the SEF Rules or the Participant’s

registration, if any, under the CEA, or under any other Applicable Law.

RULE 313 DEATH OR DISSOLUTION OF A PARTICIPANT

All rights and privileges of a Participant terminate upon, and all obligations of a Participant shall survive, the death or incapacity of

the Participant (if an individual) or the dissolution of the Participant (if an entity).

RULE 314 WITHDRAWAL OF PARTICIPANT

(a) To withdraw from the SEF, a Participant must notify the SEF following the procedures established by the SEF. Except as

otherwise required by law or regulation or by request or order of a Government Agency, such withdrawal will be effective

immediately upon receipt of the withdrawal by the SEF.

(b) Upon the effectiveness of the withdrawal of a Participant, all rights and privileges of such Participant terminate (including,

without limitation, the Trading Privileges and ability to access the Platform) immediately. The SEF may suspend Trading

Privileges prior to termination if necessary to appropriately effectuate termination. The accepted withdrawal of a Participant

shall not affect the rights of the SEF under the SEF Rules or relieve the former Participant of its Obligations under the SEF

Rules, to perform all contracts involving any Contracts entered into by such, or to pay any the SEF fees, costs, or charges

incurred, before the withdrawal. Notwithstanding the accepted withdrawal of a Participant, the withdrawn Participant remains

subject to the SEF Rules, the Obligations and the jurisdiction of the SEF for acts done and omissions made while a

Participant, and must cooperate in any SEF Proceeding under Chapter 10 as if the withdrawn Participant were still a

Participant.

RULE 315 COMPLIANCE WITH THE CEA

(a) All Participants, all Clients and Customers of any Participant that is an Account Manager and all Sponsored Persons shall

comply with the provisions of the CEA and CFTC Regulations, including the filing of reports, maintenance of books and

records, and permitting inspection and visitation by duly authorized representatives of the CFTC or Department of Justice.

RULE 316 SPONSORED ACCESS

(a) A Participant may be a Sponsoring Participant and may request that the SEF grant one or more Sponsored Person(s)

Sponsored Access, pursuant to the terms and conditions of the SEF Rules. Each Sponsored Person shall designate one or

more Authorized Persons to transact on the SEF.

(b) Upon receipt of a request for the granting of Sponsored Access, the SEF will make a determination whether or not to grant

such Sponsored Access. The SEF shall notify a Sponsoring Participant of its determination in writing. A Sponsoring

Participant’s designation of a Sponsored Person for Sponsored Access shall be effective upon the approval of the SEF. The

SEF will issue SEF User IDs for each Authorized Person of the Sponsored Person for which Sponsored Access is approved.

(c) Prior to designating a Sponsored Person, the Sponsoring Participant shall submit or cause the Sponsored Person to submit

information with respect to the Sponsored Person as required by the SEF, including information regarding the Sponsored

Person’s Authorized Persons.

(d) Sponsoring Participant Obligations. With respect to each Sponsored Person which it has designated for Sponsored Access to

the SEF, and in respect of the applicable Transactions on the SEF, the Sponsoring Participant shall:
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(1) represent and warrant to the SEF that it has entered into an Intermediary Agreement with such Sponsored Person

that satisfies the requirements set forth in Rule 301(b) and which obligates such Sponsored Person to: (i) assist the

SEF in complying with its legal and regulatory obligations, cooperate with the SEF and the CFTC in any inquiry,

investigation, audit, examination or proceeding and (ii) acknowledge that the SEF is authorized to provide information

regarding such Sponsored Person to the Regulatory Services Provider, the CFTC or any Self-Regulatory

Organization;

(2) be responsible for all Orders and Transactions placed by any Person acting on behalf of or in the name of the

Sponsored Person on the SEF as if such Orders and/or Transactions were placed by the Sponsoring Participant

(whether or not the Sponsoring Participant was aware of and/or had approved the placing of such Orders or

Transactions). Any execution occurring as a result of an Order entered by a Sponsored Person shall be binding in all

respects on the Sponsoring Participant;

(3) assist the SEF in any investigation into actual or potential violations of the SEF Rules which occur through or with

respect to the activity of each Sponsored Person. Such assistance must be timely and may include but not be limited

to, requiring the Sponsored Person to produce documents, to answer questions from the SEF, and/or appear in

connection with an investigation:

(4) suspend or terminate the Trading Privileges of a Sponsored Person or any Authorized Trader associated with such

Sponsored Person if the SEF determines that the actions of the Sponsored Person or any of its Authorized Persons

threaten the integrity of the SEF or liquidity of any Swap, or violate any SEF Rule, or if the Sponsored Person or any

of its Authorized Persons fails to cooperate in an investigation.

(e) If a Sponsoring Participant has actual or constructive notice of a violation of the SEF Rules in connection with the Sponsored

Access by its Sponsored Person and the Sponsoring Participant fails to take appropriate action, the SEF may consider that

the Sponsoring Participant has committed an act detrimental to the interest or welfare of the SEF in violation of Rule 912.

(f) The SEF may, in its sole discretion, revoke, suspend, limit, condition, restrict or qualify the designation of a Sponsored

Person, and shall notify the Sponsoring Participant of such action in accordance with SEF procedures, provided that any

decision to revoke, suspend, limit, condition, restrict or qualify the designation of a Sponsored Person shall be impartially

enforced.

(g) A Sponsoring Participant that seeks to terminate the designation of a Sponsored Person shall notify the SEF in writing,

providing such information as the SEF may require. Except as otherwise required by law or regulation or by request or order

of a Government Agency, such termination will be effective immediately upon receipt of the notification from the Sponsoring

Participant by the SEF.

(h) Upon the effectiveness of the termination of a Sponsored Person, all rights and privileges of such Sponsored Person

terminate (including, without limitation, the Trading Privileges and ability to access the Platform) immediately. The SEF may

suspend Trading Privileges prior to termination if necessary to appropriately effectuate termination. The termination of a

Sponsored Person shall not affect the rights of the SEF under the SEF Rules or relieve the former Sponsored Person of its

Obligations under the SEF Rules or to perform all contracts involving any Contracts entered into by such Sponsored Person,

before the termination. Notwithstanding the termination of a Sponsored Person, the terminated Sponsored Person remains

subject to the SEF Rules, the Obligations and the jurisdiction of the SEF for acts done and omissions made while a

Sponsored Person, and must cooperate in any SEF Proceeding under Chapter 10 as if the terminated Sponsored Person

were still a Sponsored Person.

Chapter 4 – SEF Services

RULE 401 REAL-TIME PUBLIC REPORTING

(a) In General.

(1) CFTC Regulation Part 43, which sets forth the rules regarding real-time reporting, requires certain transaction data to

be reported to a Swap Data Repository as soon as technologically practicable after Execution.

(2) The responsibilities for real-time reporting pursuant to CFTC Regulation Part 43 will vary depending on whether or

not the Transaction is executed on or pursuant to the SEF Rules.

(3) A Participant or Participant’s Counterparty must transmit all data required to be reported under CFTC Regulation

Part 43 for any Block Trades to the SEF as soon as technologically practicable after Execution, but in any event no

later than 10 minutes after Execution.
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(4) For all Transactions executed on the Platform or pursuant to the SEF Rules, including Block Trades, the SEF will

fulfill the real-time reporting obligations in CFTC Regulation Part 43 by reporting transaction and pricing data to the

DTCC, including an actual description of the underlying assets. The SEF may enter into contractual relationships

with third party service providers to transmit the Swap transaction and pricing data to a Swap Data Repository.

(5) The SEF shall have the authority to charge fees for the transmission of transaction and pricing data to a real-time

disseminator for Transactions executed on the Platform or pursuant to the rules of the SEF; provided, however, that

such fees shall be equitable and non-discriminatory.

(b) Pursuant to CFTC Regulation § 43.3(b), or any successor regulation thereto, and consistent with CFTC Regulation Part 43

and Appendix A to Part 43, the SEF will report all transaction and pricing data for Transactions executed on the Platform or

pursuant to the SEF Rules as soon as technologically practicable after Execution to a registered Swap Data Repository for

public dissemination.

(c) Pursuant to CFTC Regulation § 43.4(f)(2), or any successor regulation thereto, the SEF will report the actual notional or

principal amount for all Swaps executed on or pursuant to the rules of the SEF, including those of any Block Trade, to a

registered Swap Data Repository. However, this amount may be rounded or capped by such Swap Data Repository prior to

public dissemination.

(d) The SEF will not disclose transaction or pricing data for any Transactions to the general public prior to the public

dissemination of such data. However, the SEF may transmit such data on a non-discriminatory basis to Participants and any

market participants subscribing to the SEF for information services after or at the same time that the SEF transmits such data

to a registered Swap Data Repository pursuant to Rule 401(b).

(e) Real-time dissemination of Block Trades will be done in accordance with Rule 602.

RULE 402 REGULATORY REPORTING

(a) Reporting Creation Data.

(1) CFTC Regulation Part 45, which sets forth the rules regarding regulatory reporting, requires Creation Data for any

Transaction to be reported to a single Swap Data Repository after Execution. Creation Data includes the Primary

Economic Terms and Confirmation Data.

(2) The responsibilities for regulatory reporting pursuant to CFTC Regulation § 45.3, or any successor regulation thereto,

will vary depending on whether or not the Transaction is executed on or pursuant to the SEF Rules and whether or

not the Transaction is cleared.

(3) A Participant or Participant’s Counterparty must transmit all data required to be reported under CFTC Regulation

Part 45 for any Block Trades to the SEF as soon as technologically practicable after Execution.

(4) If both Counterparties are Swap Dealers, or both Counterparties are Major Swap Participants, or both Counterparties

are neither Swap Dealers nor Major Swap Participants that are financial entities as defined in CEA section

2(h)(7)(C), or both Counterparties are neither Swap Dealers nor Major Swap Participants and neither Counterparty is

a financial entity as defined in CEA section 2(h)(7)(C), then the seller of risk in the currency which is first, when

sorted alphabetically by ISO code, would bear responsibility to report the trade.

(5) For all Transactions executed on the Platform or pursuant to the SEF Rules, including Block Trades, the SEF will

report the Primary Economic Terms and Confirmation Data to the DTCC. The SEF may enter into contractual

relationships with third party service providers to transmit the Primary Economic Terms and Confirmation Data to

such Swap Data Repository.

i. TR SEF relies upon CFTC No-Action Letter 17-17, titled “Extension of No-Action Relief for Swap Execution

Facility Confirmation and Recordkeeping Requirements under Commodity Futures Trading Commission

Regulations 37.6(b), 37.1000, 37.1001, 45.2, and 45.3(a)” in reporting Confirmation Data to the DTCC. This

No-Action Letter will expire on the effective date of revised CFTC Regulations that amend the CFTC’s

requirements regarding SEF confirmations.
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(6) Participant must provide the SEF with sufficient information to enable the SEF to report all Creation Data, including

without limitation:

i. The Legal Entity Identifier or CICI of the Participant;

ii. A yes/no indication of whether Participant is a Swap Dealer with respect to the product with respect to which

the Order is placed;

iii. A yes/no indication of whether Participant is a Major Swap Participant with respect to the product with

respect to which the Order is placed.

iv. A yes/no indication of whether Participant is a financial entity as defined in CEA section (2)(h)(7)(C);

v. A yes/no indication of whether Participant is a U.S. Person;

vi. If applicable, an indication that Participant will elect the End-User Exception for any Swap resulting from the

order;

vii. If the Transaction will be allocated:

1. An indication that the Transaction will be allocated.

2. The Legal Entity Identifier or CICI of the agent.

3. An indication of whether the Swap is a post-allocation swap.

4. If the swap is a post-allocation swap, the Unique Swap Identifier of the original Transaction

between the Reporting Counterparty and the agent.

(7) The SEF shall have the authority to charge fees for any services provided pursuant to this Rule 402; provided,

however, that such fees shall be equitable and non-discriminatory.

(b) Reporting Continuation Data.

(1) CFTC Regulation Part 45 requires Continuation Data to be reported to the same Swap Data Repository referenced in

Rule 401(a)(1) during the life of any Transaction. Continuation Data includes life-cycle event data or state data, each

as defined in CFTC Regulation § 45.1, or any successor regulation thereto, and Valuation Data.

(2) [Reserved]

(3) Pursuant to CFTC Regulation § 45.4(c), Continuation Data for any uncleared Transaction, whether or not the

Transaction is executed on a Swap Execution Facility, will be reported to the relevant Swap Data Repository by the

Reporting Counterparty.

(4) The SEF will have no obligation to fulfill any requirements to report Continuation Data for any Participant, including

Valuation Data.

(5) If the SEF fulfills any requirements to report Continuation Data for any Participant that is a Reporting Counterparty,

such Participant will at all times remain responsible for the performance of any and all regulatory reporting

requirements imposed on such Participant under CFTC Regulation Part 45.

RULE 403 MAINTENANCE OF BOOKS AND RECORDS BY THE SEF

(a) The SEF shall keep, or cause to be kept, full, complete and systematic records, together with all pertinent data and

memoranda, of all activities relating to the business of the SEF with respect to Swaps. Such records shall include, without

limitation, timestamps required to be maintained under CFTC Regulation § 43.3, a complete audit trail for all Swaps executed

on or subject to the rules of the SEF, investigatory files, disciplinary files, all books and records required to be maintained
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pursuant to the CEA and CFTC Regulations, including CFTC Regulation Part 37. The SEF shall retain all such books and

records, including, without limitation, a record of each Transaction executed on the Platform, in electronic form for at least five

(5) years.

(b) All records relating to Swaps, as described in Rule 403(a) above and pursuant to CFTC Regulation § 45.2, shall be kept

throughout the life of the Swap and for at least five (5) years following the final termination of the Swap. Records relating to

Swaps shall be readily accessible via real time electronic access by the SEF throughout the life of the Swap and for two (2)

years following the final termination of the Swap, and shall be retrievable by the SEF within three (3) business days through

the remainder of the period following final termination of the Swap during which it is required to be kept, pursuant to CFTC

Regulation § 45.2(e)(1). As required by CFTC Regulation §§ 1.31 and 45.2(h), all books and records kept pursuant to this

Rule 403, including audit trail data and reconstructions, shall be made available to the CFTC in a form, manner and time that

is acceptable to the CFTC, and shall be open to inspection and examination by the CFTC, the Department of Justice, the

Securities and Exchange Commission, and by any other regulator as authorized by the CFTC. Copies of all such records shall

be provided, at the expense of the SEF, to the CFTC upon request, by electronic means, in hard copy, or both, as requested

by the CFTC, except that copies of records originally created and exclusively maintained in paper form may be provided in

hard copy only.

(c) The SEF shall include the Unique Swap Identifier for a swap in all of its records and all of its swap data reporting concerning

that Swap, from the time it creates or receives the Unique Swap Identifier, throughout the existence of the Swap and for as

long as any records are required by the CEA or CFTC Regulations to be kept by the SEF concerning the Swap, regardless of

any life cycle events or any changes to state data concerning the Swap, including, without limitation, any changes with

respect to the Counterparties to or the ownership of the Swap.

(d) The SEF shall use the Legal Entity Identifier or CICI for each Counterparty in all of its records and all of its swap data

reporting pursuant to CFTC Regulation Part 45.

(e) The SEF shall use the Unique Product Identifier according to the system designated by the Commission, or if no such system

has been designated, the internal product identifier or product description used by the Swap Data Repository to which a Swap

is reported, in all of its records and all of its swap data reporting pursuant to CFTC Regulation Part 45.

RULE 404 TRANSACTION CONFIRMATIONS

(a) The SEF will confirm each Transaction at the same time as Execution of the Transaction. The economic terms

specific to the Transaction agreed to by the Participants on the SEF shall be reflected by the SEF in a written

communication containing all of the terms of the Transaction (the “Trade Communication”) sent to the

applicable Participants, which shall notify Participants that a Transaction has been executed.

(1) The Trade Communication, together with the previously-negotiated freestanding agreements between

the counterparties (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 the applicable Participants are party

and which are incorporated by reference in the Trade Communication (the “Terms Incorporated by

Reference”) shall, taken together, comprise all of the terms of such Transaction and constitute a

confirmation for purposes of CFTC Regulation § 37.6(b) and shall be deemed to be the “SEF

Confirmation”.

(2) In satisfaction of the obligations imposed on the SEF under CFTC Regulation § 37.6(b): (i) each Trade

Communication is deemed to incorporate the Terms Incorporated by Reference set forth in this Rule

404, and (ii) the Trade Communication shall state that it incorporates by reference the Terms

Incorporated by Reference.

(3) The Trade Communication shall legally supersede any contradictory terms in the Terms Incorporated

by Reference. Therefore, 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. The Trade Communication shall state that it legally supersedes any contradictory terms

in the Terms Incorporated by Reference.
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(4) [Reserved]

(b) A SEF Confirmation shall be deemed to be a binding and fully enforceable confirmation of the Transaction

between such parties.

(c) A SEF Confirmation shall be deemed to be fully, and mutually executed by the parties, “signed” and “in writing”

for any and all purposes, and the resulting SEF Confirmation shall constitute the controlling confirmation with

respect to the applicable Transaction.

(d) Participant agrees not to contest the legally binding nature or enforceability of any Transaction entered into or

negotiated on the Platform and further agrees not to contest or assert any defense to the validity or

enforceability of any Transaction on the basis that such Transaction was executed or negotiated electronically

or on the basis of any law requiring agreements to be in writing or to be signed by the parties. Participant

hereby waives any and all right to assert any such claims.

(e) Participant agrees to use commercially reasonable efforts to promptly review all SEF Confirmations and to

reconcile any data or other discrepancies.

RULE 405 AUDIT TRAIL PROGRAM

(a) The SEF’s audit trail permits it to track customer orders from the time of receipt through fill, allocation, or other disposition,

and includes both order and trade data. The audit trail program includes all original source documents and an electronic

transaction history database. The electronic transaction history database includes a history of all indications of interest,

requests for quotes, orders, and trades entered into the Platform, including all orders and trades, and order modifications and

cancellations. An adequate transaction history database also includes:

(1) All data that is input into the trade entry or matching system for the transaction to match and clear;

(2) Customer type indicator code;

(3) Timing and sequencing data adequate to reconstruct trading; and

(4) Identification of each account to which fills are allocated.

(b) The SEF will enforce its audit trail and recordkeeping requirements through at least annual reviews of all Participants to verify

their compliance with the SEF’s audit trail and recordkeeping requirements. Such reviews will include, but are 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 trade records to test for accuracy and improper use.

(c) The SEF’s audit trail enforcement program will identify Participants that have failed to maintain high levels of compliance with

such requirements and will sanction Participants for deficiencies. Sanctions will not include more than one warning letter for

the same violation of audit trail or recordkeeping requirements within a rolling twelve month period.

RULE 406 MONITORING OF TRADING AND TRADE PROCESSING

The SEF will monitor trading on the Platform in order to prevent manipulation, price distortion, and disruptions of the delivery or

cash settlement process through surveillance, compliance, and disciplinary practices and procedures, including through the realtime monitoring of trading, and comprehensive trade reconstruction.

RULE 407 PUBLICATION OF TRADING INFORMATION

The SEF will publish trading information as required by CEA Section 5h(f)(9) and Parts 16 and 37 of CFTC Regulations.
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Chapter 5 – Obligations of Participants

RULE 501 DUTIES AND RESPONSIBILITIES OF PARTICIPANTS

(a) Each Participant shall (and shall cause all of its Authorized Persons and Clients, Customers and/or Sponsored Persons, if

applicable, to):

(1) use the Platform in a responsible manner and not for any improper purpose;

(2) use the Platform only to conduct SEF Activity;

(3) conduct all SEF Activity in a manner consistent with SEF Rules and Obligations;

(4) comply with all SEF Rules and Obligations and act in a manner consistent with each SEF Rule and Obligation;

(5) comply with all rules of the Regulatory Service Provider, if any, to the extent applicable to it, and act in a manner

consistent with the rules of the Regulatory Service Provider, if any, to the extent applicable;

(6) observe high standards of integrity, market conduct, commercial honor, fair dealing, and just and equitable principles

of trade while conducting or attempting to conduct any SEF Activity, or any aspect of any business connected with or

concerning the SEF;

(7) not knowingly mislead or conceal any material fact or matter in any dealings or filings with the SEF or in response to

any SEF Proceeding;

(8) employ practices to monitor and enforce compliance with risk limits; and

(9) keep, or cause to be kept, complete and accurate books and records, including, without limitation, all books and

records of its SEF Activity and his or her activity in the underlying commodity and related derivatives markets, and all

books and records required to be maintained pursuant to the CEA, the CFTC Regulations or the SEF Rules, for the

period required by Applicable Law, and make such books and records available for inspection by a representative of

the SEF, the Regulatory Service Provider, the CFTC, or the Department of Justice, as required under CFTC

Regulation 1.31.

(b) Each Participant shall:

(1) be financially responsible for all Orders and Transactions in Contracts effected by such Participant, and for any use

of the Platform made by Participant, the Participant’s Authorized Persons, or any Person using the Participant’s User

ID.

(2) be responsible for promptly informing the SEF of any material changes to the information provided to the SEF by the

Participant pursuant to Rules 301 and 302.

RULE 502 REQUIRED DISCLOSURES TO THE SEF

(a) Each Participant shall immediately notify the Market Regulation Department upon becoming aware of any of the following

events, in each case, with respect to the Participant’s status which relates to or may affect its participation or conduct on the

SEF:

(1) any material change to the contact information provided to the SEF;

(2) any damage to, or failure or inadequacy of, the systems, facilities or equipment of the Participant to effect

transactions pursuant to the SEF Rules or to timely perform the Participant’s financial obligations under or in

connection with Contracts;

(3) any refusal of admission, or involuntary withdrawal of the Participant for membership in, any Self-Regulatory

Organization, Contract Market or Derivatives Clearing Organization;
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(4) any expulsion, suspension or fine in excess of $25,000, cease and desist order, denial of trading privileges, censure

or other sanction or remedy (whether through an adverse determination, voluntary settlement or otherwise) imposed

on the Participant by any Self- Regulatory Organization, Contract Market or Derivatives Clearing Organization

registered with the CFTC or, with respect to SEF Activity, any relevant Government Agency;

(5) any indictment or conviction of, or any confession of guilt or plea of guilty or nolo contendere by, the Participant (or, if

the Participant is an entity, by any of its principals or senior officers) for any felony or misdemeanor involving, arising

from, or related to, the purchase or sale of any commodity, swap, Futures contract, Option, security, securities

futures product or other financial instrument, or involving or arising from fraud or moral turpitude;

(6) the Participant becoming the subject of a petition for bankruptcy;

(7) the appointment of a receiver, trustee or administrator for the Participant;

(8) the presentment of a petition, or the passing of a resolution, for the winding-up of Participant;

(9) the commencement of proceedings for the dissolution of Participant; or

(10) the occurrence of an event of insolvency with respect to the Participant.

RULE 503 INSPECTIONS BY THE SEF

(a) The SEF (or the Regulatory Services Provider or other authorized representative) shall have the right with such prior

reasonable advance notice as is practicable under the circumstances, in connection with determining whether all SEF Rules

and Obligations are being, will be, or have been complied with by the Participant, to:

(1) inspect systems, equipment and software operated by the Participant in connection with its SEF Activity, wherever

located; and/or

(2) copy or reproduce any data to which the SEF has access under this Rule 503.

(b) Such books and records, systems, equipment and software shall be made available to the SEF and the Regulatory Services

Provider, and their respective authorized representatives, during regular business hours. The SEF and the Regulatory

Services Provider and their respective authorized representatives agree to adhere to Participant’s reasonable physical access

and security procedures.

(c) The Market Regulation Department may require a Participant to furnish (periodically or on a particular occasion) information

concerning the Participant’s SEF Activity. Such information includes but is not limited to, the Participant’s open trading

positions or Contracts to which the Participant is a party.

(d) The Market Regulation Department may examine (periodically or on a particular occasion) the books and records of any

Participant or any Customer or Client of a Participant, or any Sponsored Person that relate to SEFActivity.

(e) Each Participant shall provide the Regulatory Services Provider with the same access to their books and records and offices

as they are required to provide the SEF under the SEF Rules and Applicable Law.

(f) The SEF shall provide information in its possession to the CFTC or the Regulatory Services Provider upon request in a form

and manner approved by the CFTC. The SEF shall also share information with other regulatory organizations, data

repositories, and reporting services as required by the CFTC or as otherwise necessary and appropriate to fulfill its selfregulatory and reporting responsibilities. Appropriate information-sharing agreements can be established with such entities or

the CFTC can act in conjunction with the SEF to carry out such information sharing.

(g) Without limiting anything in this Rule 503 or elsewhere in the SEF Rules, a Participant shall furnish the Terms Incorporated by

Reference to the SEF upon request. Upon request from the CFTC, the SEF shall request from Participants the Terms

Incorporated by Reference and furnish such documents to the CFTC as soon as they are available.
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RULE 504 MINIMUM REQUIREMENTS FOR PARTICIPANTS

(a) Each Participant shall comply with the provisions of Applicable Law, including but not limited to the rules and regulations of

any Government Agency that are imposed on a Participant relating to minimum financial requirements (if applicable),

reporting and recordkeeping requirements, and any mandatory clearing requirements.

(b) [Reserved]

(c) Each Participant who is a Swap Dealer or Major Swap Participant shall be responsible for compliance with any mandatory

trading requirements under CEA Section 2(h)(8) and CFTC regulations thereunder.

(d) For a Non-Cleared Swap executed on or subject to the rules of the SEF, each Participant party must have entered into an

agreement governing the execution and settlement of the Swap with the prospective Counterparty to such Swap prior to

placing any Order related to such Swap.

(e) A copy of any notice or written report that a Participant is required to file with the CFTC pursuant to CFTC Regulation § 1.12,

or any successor regulation thereto, shall be concurrently provided to the SEF.

(f) A Participant who violates any CEA provision or CFTC Regulation referred to in this Rule 504 shall be deemed to have also

violated this Rule 504.

RULE 505 RECORDKEEPING REQUIREMENTS

(a) In General.

(1) Each Person granted Trading Privileges must maintain or cause to be maintained records for all books and records

required to be maintained in accordance with Applicable Law, including CFTC Regulations 1.31 and 1.35, and SEF

Rule 501(a)(9).

(b) Bunched Orders and Orders Eligible for Post Execution Allocation.

(1) Bunched Orders must be allocated and recorded in accordance with CFTC Regulation § 1.35(b)(5), or any successor

regulation thereto, and the NFA’s Interpretative Notice related to Compliance Rule 2-10 or any successor regulations.

(c) Records of Underlying Commodity Activity and Related Transactions.

(1) As required by CFTC Regulations §§ 1.31 and 37.404, each Participant, Customer, Client and Sponsored Person

must keep records of its trading on the SEF, including records of its activity in the commodity underlying any Swap

and trading on related derivatives markets and make such records available, upon request, to the SEF, the CFTC,

and the Department of Justice.

RULE 506 CONFIDENTIALITY OF FINANCIAL AND OTHER INFORMATION

All information and data obtained or received by the Market Regulation Department from inspections of accounting and other

records, quarterly balance sheets and declarations or reports on financial condition will be treated as confidential by the SEF;

however, this Rule 506 does not supplant Rules 210, 1003(c), 1201(e), or any other requirement of Applicable Law.

RULE 507 AUTHORITY TO REPORT

Whenever the SEF learns that Participant has failed to file any notice or written report required by CFTC Regulation § 1.12, or any

successor regulation thereto, the SEF will immediately report this failure to the CFTC. The SEF may impose such conditions or

restrictions on the business and operations of Participant that has failed to file any such notice or written report as the SEF may

deem necessary or appropriate for the protection of Customers, other Participants, or the SEF.

RULE 508 BROKERS AND ACCOUNT MANAGERS

(a) No Participant acting as a broker or Account Manager shall carry an account for a Customer or enter an Order in the name of

or on behalf of a Client unless the Participant has entered into a written agreement with the Customer or Client containing
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such terms as may from time to time be prescribed in these SEF Rules, including without limitation, those rules contained in

SEF Rule 301(b).

(b) No Participant shall engage in soliciting or accepting an Order for the Contract for a Participant, Customer or Client unless the

Participant has entered into a written agreement with the Participant, Customer or Client obtaining such terms as may from

time to time be prescribed in these SEF Rules.

RULE 509 TREATMENT OF CUSTOMER FUNDS AND SECURITIES

Each Participant that is required to be registered with any Government Agency, including the CFTC and the U.S. Securities and

Exchange Commission or any Self-Regulatory Organization, shall comply with the provisions of Applicable Law, including but not

limited to the rules and regulation such Government Agency imposes on a Participant relating to the treatment of Customer funds

and the maintenance of books and records with respect thereto. Any Participant that violates any of the aforementioned

Government Agency Regulations shall be deemed to have violated this Rule 509.

RULE 510 DISCLOSURE REQUIREMENTS; KNOW YOUR COUNTERPARTY REQUIREMENTS

(a) Each Participant must comply with all disclosure requirements set forth in applicable CFTC Regulations and rules of the

Regulatory Service Provider, if any. Any such disclosure may be combined with a disclosure regarding the existence of

financial interests held by the Participant in the SEF or any other Swap Execution Facility.

(b) Participants that are Swap Dealers or Major Swap Participants shall verify that each potential Counterparty is an Eligible

Contract Participant with respect to each Swap as provided in Subpart H of Part 23 of the CFTC Regulations, or any

successor regulations related to external business conduct standards for Swap Dealers and Major Swap Participants.

(c) Participants that are Futures Commission Merchants must verify that each of their Customers are Eligible Contract

Participants.

(d) Participants that are Account Managers must verify that each of their Clients is Eligible Contract Participants.

RULE 511 INFORMATION REGARDING ORDERS

(a) In accordance with the provisions of SEF Rule 1206, the SEF will make information regarding Orders (including prices bid or

offered), trades and any other matters it may deem appropriate available to Participants and other Persons at such times and

in such manner (whether through the Platform, a ticker, financial information services or otherwise) as it may consider

necessary or advisable from time to time.

(b) Each Participant or other Person receiving any such information through the Platform may redistribute such information only

to such extent and in such manner as may be permitted by the SEF from time to time.

RULE 512 CUSTOMER TYPE INDICATOR (CTI) CODES

(a) Each Participant must identify each transaction executed on the Platform on the record of transactions submitted to the SEF

with the correct CTI Code. The CTI Codes are as follows:

(1) CTI 1- Transactions initiated and executed by a Participant for his own account, for an account he controls or for an

account in which he has ownership or financial interest.

(2) CTI 2- Transactions executed for the proprietary account of a Clearing Member or non-Clearing memberfirm.

(3) CTI 3- Transactions where an individual Participant or Authorized Person executes for the personal account of

another individual Participant, for an account the other individual Participant controls or for an account in which the

other individual Participant has ownership or financial interest.

(4) CTI 4- Any transaction not meeting the definition of CTI 1, 2 or 3.

RULE 513 CANCELED TRADES & AMENDED TRADE INFORMATION

(a) If the reporting party to a Transaction executed on or pursuant to the Rules of the SEF (including Prime Broker Trades)
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becomes aware of a discrepancy, error or omission in swap transaction and pricing data reported to a Swap Data Repository,

or if a Transaction executed on or pursuant to the Rules of the SEF (including Prime Broker Trades) is canceled or amended,

such discrepancy, error, omission, cancellation or amendment (as the case may be) must be reported to the SEF by the

reporting party as soon as technologically practicable after discovery of such discrepancy, error or omission, or canceling or

amending such Transaction (according to procedures of the SEF, as may be amended from time to time), so that the SEF

may accurately amend the audit trail and report trade information according to Parts 16, 43 and 45 of the CFTC Regulations.

(1) If a Transaction was submitted for clearing and contains an operational or clerical error (an “Error Trade”), the parties

to such Transaction shall be permitted to enter into an offsetting or correcting trade subject to the following:

i. If the Transaction was rejected from clearing, the parties shall be permitted to execute and submit for

clearing a new Transaction with the same terms and conditions as the Error Trade other than any

corrections to any operational or clerical error and the time of execution (a “Correcting Trade”). Execution of

a Correcting Trade must occur as soon as technologically practicable, but no later than one hour after a

registered Derivatives Clearing Organization, or a derivatives clearing organization that the Commission has

determined is exempt from registration, provides notice of the rejection.

ii. If the Transaction was accepted for clearing, the parties shall be permitted to execute and submit for

clearing an offsetting trade with terms and conditions that economically reverse an error trade that was

accepted for clearing.

iii. If a Correcting Trade is rejected from clearing, the parties to the Transaction shall not be permitted to

execute another Correcting Trade. 

(b) If a Participant that is a Counterparty to a Prime Broker Trade requests the cancellation of that Prime Broker Trade, the

Participant must send a cancellation notice to the SEF stating the name and contact information of the Prime Broker for the

Prime Broker Trade and the reason for cancellation. If the Prime Broker confirms the cancellation, the SEF will cancel the

Prime Broker Trade.

(c) A Prime Broker shall have the right to cancel any Prime Broker Trade that is: (i) executed in excess of a limit established by

the Prime Broker with respect to the Prime Broker Trade, (ii) executed by a Person that was not authorized by the Prime

Broker, or (iii) executed for an unauthorized product. The Prime Broker shall communicate the cancellation directly to the SEF

within 48 hours after the execution of the Prime Broker Trade and indicate the reason for the cancellation.

(d) Reports or notices of canceled or amended Transactions described in this Rule 513 may be provided to the SEF using the

electronic cancellation and amendment tool, if available, or by contacting SEF support.

Chapter 6 – Supported Transactions

RULE 601 GENERAL

(a) The SEF supports Permitted Transactions in Swaps not intended to be cleared, through the execution methods

detailed in Chapter 7.

(b) [Reserved]

RULE 602 BLOCK TRADES

(a) [Reserved]

(b) The SEF will publish the list of contracts for which it permits and facilitates the bilateral trading and execution of Block Trades

on its website.

(c) The following shall govern Block Trades:

(1) Each Counterparty to a Block Trade (or a Person, Customer or Client on whose behalf a Block Trade is executed)

must be an Eligible Contract Participant.
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(2) Parties to a Swap with a notional amount at or above the Appropriate Minimum Block Size must elect to have the

Swap treated as a Block Trade in order for the Swap to constitute a Block Trade pursuant to this Chapter 6.

(3) A Block Trade must be for a quantity that is at or in excess of the Applicable Minimum Block Size. Orders may not be

aggregated for different accounts in order to achieve the minimum transaction size unless done by a Person who:

(a) Is either: (i) a commodity trading advisor registered under Section 4n of the CEA, or exempt from

registration under the CEA, or a principal thereof, who has discretionary trading authority or directs client

accounts, (ii) is an investment adviser who has discretionary trading authority or directs client accounts

and satisfies the criteria of CFTC Regulation § 4.7(a)(2)(v), or (iii) is a non-U.S. person, as defined in

CFTC rules, regulations and/or interpretations who performs a similar role or function as the persons

described in Rule 602(c)(3)(a)(i) or (ii) and is subject as such to foreign regulation; and

(b) Has more than $25,000,000 in total assets under management.
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(4) A broker shall not execute any order by means of a Block Trade for a Customer unless the broker has received prior

written instruction or consent from the Customer to do so. Such instruction or consent may be provided in the power

of attorney or similar document by which the Customer provides the broker with discretionary trading authority or the

authority to direct the trading in its account.

(5) The price at which a Block Trade is executed must be fair and reasonable in light of (i) the size of the 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 markets or the

Participants to the Block Trade.

(6) One of the Counterparties or the broker of one of the Persons party to the Block Trade must ensure that each Block

Trade is reported to the SEF within the time limit set forth in Rule 401(a)(3).

(7) Block Trades must be reported to the SEF in accordance with the SEF approved reporting method and must include

all of the data required by CFTC Regulations Part 43 and 45. The SEF will transmit Block Trade transaction and

pricing data, including a notice that the Counterparties have elected to treat the Swap as a Block Trade, to a Swap

Data Repository as soon as technologically practicable after receipt of such data. CFTC Regulations prohibit any

Swap Data Repository from publicly disseminating this data until the expiration of certain time delays as specified in

CFTC Regulation § 43.5, or any successor regulation thereto.

(8) An executed Block Trade must become a part of the SEF’s audit trail.

RULE 603 PRIME BROKER TRADES

(a) A Participant may execute a Prime Broker Trade on or pursuant to the rules of the SEF in accordance with the provisions of

this Rule 603, in addition to otherwise applicable provisions of the Obligations.

(b) Prior to negotiating any Prime Broker Trade on or pursuant to the rules of the SEF, a Participant must have in place a Prime

Broker Agreement, which shall satisfy those rules contained in SEF Rule 301(b).

(c) Each Participant involved in a Prime Broker Trade must notify the Prime Broker as soon as technologically possible of each

Prime Broker Trade executed on or pursuant to the rules of the SEF to which the Prime Broker is a Counterparty, and provide

to the Prime Broker the Confirmation for the Prime Broker Trade issued by the SEF.

Chapter 7 – Execution Methods

RULE 701 GENERAL

Transactions executed on the SEF must be executed either on the SEF Central Limit Order Book (“CLOB”), the SEF RFQ Platform

(“RFQ Platform”), or the SEF RFS Platform (“RFS Platform”) pursuant to this chapter.

RULE 702 CENTRAL LIMIT ORDER BOOK (“CLOB”)

(a) The CLOB is an electronic price-time priority central limit order book in which Participants trade against firm quotes posted by

other Participants. When a Participant enters a bid or offer on the CLOB, other Participants are notified that such bid or offer

has been placed by the bid or offer appearing on the CLOB. If there are multiple bids and offers that have the same price, the

earliest to arrive in the CLOB will be the bid or offer to which the order is matched. If the order exceeds the quantity of the bid

or offer, the Participant may be filled at the next, best bid or offer for their order.

(b) [Reserved]

(c) Orders submitted can only match with quotes posted by Participants with whom the order submitter has an agreement

governing the execution and settlement of Swaps.

(d) All Orders submitted to the CLOB are anonymous; provided, that, for Permitted Transactions that are not intended to be

submitted for clearing contemporaneously with execution, the identity of each Counterparty is disclosed to the other

Counterparty in the SEF Confirmation at the time of confirmation.
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(e) The CLOB supports the following types of Orders:

(1) For non-deliverable forwards: limit orders, limit orders with discretion, limit orders with reserve, and hidden orders.

i. A limit order has a “limit” price, which is the top price to be paid for a buy and the lowest price to be given

for a sell Order.

ii. A limit order with discretion is a limit order with a discretion value, which allows the Participant placing the

Order to post a limit order and then take liquidity within a discretionary amount using the total Order

quantity.

iii. A limit order with reserve is a limit order where the Participant placing the Order can control the visible

quantity. The “Show” quantity displays a portion of the “Total” quantity and holds the balance in reserve,

without losing time price priority.

iv. A hidden order is a passive Order that is not visible to other market participants. A hidden bid or offer will

be executed when all other visible bids or offers (as the case may be) at the same price have been

exhausted.

(2) For options: limit orders.

i. A limit order has a “limit” price, which is the top price to be paid for a buy and the lowest price to be given

for a sell Order.

(f) The CLOB supports the following values for Time in Force:

(1) Day: A Day order may rest on the book for the duration of the trading day or until the Participant cancels it. Any

portion that has not executed by the end of the trading day will expire.

(2) Immediate or Cancel (“IOC”): An IOC order must be executed in whole or in part on the Order Book as soon as it is

received. Any remaining quantity is cancelled.

(g) To enter a bid or offer into the CLOB, a Participant must:

(1) Open an order entry window by clicking on a “Bid,” “Offer,” “Price” or “Quantity” button;

(2) In the order entry window, click on the “Bid” or “Offer” button;

(3) Adjust “Order Type,” “Price,” “Quantity” and “Time in Force” as need be; and

(4) Click the “Place Order” button.

(h) Each Participant entering an Order on the CLOB must provide, without limitation:

(1) Identification of the Participant;

(2) Identification of whether the Order is a bid or an offer;

(3) Order type;

(4) Price;

(5) Quantity; and

(6) Time in Force.
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RULE 703 REQUEST FOR QUOTE PLATFORM (“RFQ PLATFORM”)

(a) Transactions may be negotiated by Participants and their Counterparties by use of the RFQ Platform. Through the RFQ

Platform, Participants can transmit a request for a quote (“RFQ”) to buy or sell a specific instrument to other Participants,

to which all such Participants may respond. The RFQ Platform is a fully disclosed trading system.

(b) [Reserved]

(c) [Reserved]

(d) An RFQ may be sent to any Counterparty with whom the Participant has an agreement governing the execution and

settlement of Swaps.

(e) Negotiation Process

(1) The negotiation process on the RFQ Platform is initiated by entry of an RFQ by an RFQ requestor on the

Platform. A Participant initiating an RFQ must provide, without limitation:

i. Identification of the Participant;

ii. Identification of whether the request is for a bid, offer, or a two-way quote; and

iii. Quantity.

(2) An RFQ acts as a non-binding solicitation of a non-binding quote and provides essential economic terms

sufficient for any RFQ requestor’s Counterparty to formulate a responsive quote.

(3) In response to an RFQ, any potential Counterparty receiving an RFQ may reply with a responsive quote.

Responsive quotes to RFQs are indicative in that they are a solicitation of an offer to deal.

(4) In the event that a responsive quote is acceptable to the requestor, the requestor can accept the quote and a

request to deal will be sent to the responder. If the responder accepts the request, a legally enforceable

transaction arises and the RFQ process concludes. If the responder rejects the request, the RFQ process

concludes and no transaction arises.

(5) [Reserved]

(6) In the event that the initial responsive quote from the Counterparty or any resting bid or offer from the CLOB is not

acceptable to the RFQ requestor, the RFQ responders may continue sending responsive quotes until an

acceptance is issued or the RFQ process is terminated without a transaction.

RULE 704 REQUEST FOR STREAM PLATFORM (“RFS PLATFORM”)

(a) Transactions may be negotiated by Participants and their Counterparties by use of the RFS Platform. Through the RFS

Platform, Participants can transmit a request for a stream (“RFS”) subscription to buy or sell a specific instrument from

other Participants, to which all such Participants may respond. The RFS Platform is a fully disclosed trading system.

(b) [Reserved]

(c) [Reserved]

(d) An RFS may only be sent to a Counterparty with whom the Participant has an agreement governing the execution and

settlement of Swaps.

(e) In response to an RFS stream subscription, any potential Counterparty receiving an RFS may reply with a responsive

stream of quotes.

(f) Negotiation Process

(1) Once the requestor has completed the subscription process, the requestor may submit a limit order to the RFS

Platform. A limit order for an RFS must include without limitation:
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i. Identification of the Participant;

ii. Identification of whether the Order is a bid or an offer;

iii. Quantity; and

iv. Time in Force.

(2) The requestor can choose either a “Day” order or an “immediate or cancel” (“IOC”) order for Time in Force. If the

limit order is marketable it will be sent to the Counterparty of the requestor’s choice, or if the requestor elects to

have the RFS Platform choose, the RFS Platform will send the order to the responder with the best price. If the

limit order is not marketable, it will be held in the RFS platform until the requestor cancels the order or the order

becomes marketable.

(3) In the event that a marketable limit order is sent to a responder, the responder can choose to accept or reject the

order. If the responder accepts the order, a legally enforceable transaction arises and the RFS process for this

order concludes. If the responder rejects the order, the RFS process for this order concludes.

(4) [Reserved]

(5) The requestor will continue to receive streaming quotes from a responder until such time as the requestor

unsubscribes from the responder’s stream or the responder stops sending quotes.

RULE 705 CONFIRMATION PROCEDURES AND RECORDS.

(a) Each completed Transaction shall be confirmed by a SEF Confirmation to each Participant party thereto by technical

means as specified in the SEF Rules and in the form and format set forth in Rule 404.

(b) [Reserved]

RULE 706 LEGAL CERTAINTY FOR SEF TRADES.

A transaction entered into on or pursuant to the SEF Rules shall not be void, voidable, subject to rescission, otherwise

invalidated, or rendered unenforceable as a result of:

(a) a violation by the SEF of the provisions of Section 5h of the CEA or CFTC Regulations;

(b) any CFTC proceeding to alter or supplement a Rule, term, or condition under Section 8a(7) of the CEA or to declare an

emergency under Section 8a(9) of the CEA; or

(c) any other proceeding the effect of which is to:

(1) alter or supplement a specific term or condition or trading rule or procedure; or

(2) require the SEF to adopt a specific term or condition, trading rule or procedure, or to take or refrain from

taking a specific action.

RULE 707 POST-TRADE ANONYMITY.

(a) Pursuant to the Commission Regulation 37.9(df), neither the SEF nor any person that is subject to its rules may, directly or

indirectly, including through a third-party service provider, disclose the identity of a counterparty for swaps that are executed,

pre-arranged or pre-negotiated anonymously on or pursuant to the rules of the SEF and that are intended to be submitted for

clearing.

(b) The compliance date for this Rule 707 for swaps that are subject to the trade execution under section 2(h)(8) of the Act is

November 1, 2020. The compliance date for this rule for swaps that are not subject to the trade execution requirement under

section 2(h)(8) of the Act is July 5, 2021.

Chapter 8 – [Reserved]
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Chapter 9 – Trading Practices and Business Conduct

RULE 901 SCOPE

This Chapter 9 applies to all transactions in Contracts, except as otherwise specifically provided herein.

RULE 902 PROCEDURES

(a) With respect to trading on or though the Platform, the SEF may adopt, without limitation, procedures relating to transactions in

Contracts and trading on the Platform, including procedures to:

(1) disseminate the prices of bids and offers on, and trades in, Contracts;

(2) record Contracts and SEF Activity;

(3) perform market surveillance and regulation on matters affecting Contracts and SEF Activity;

(4) establish limits on the number and/or size of Orders that may be submitted by a Participant through thePlatform;

(5) establish limits on the number of Contracts that may be held by a Customer or Participant;

(6) establish a limit on the maximum daily price fluctuations for any Contract and provide for any related restriction or

suspension of trading in the Contract; and

(7) require a suspended or expelled Participant, or a Participant with restricted trading rights, to have Contracts

executed for the Participant to reduce or eliminate any open position or exposure to price changes for the Participant

in any Contract.

(b) The SEF may, in its discretion and at any time, amend any procedures adopted pursuant to Rule 902(a), and will publish the

amendments in a Notice to Participants or in any other manner determined appropriate by the SEF.

RULE 903 BUSINESS DAYS AND TRADING HOURS

Except as provided in Rule 209 with respect to Emergencies, the SEF shall determine and publish a Notice to Participants listing

the Business Days and Holidays of the SEF and the Trading Hours for each Contract.

RULE 904 RULE VIOLATIONS

It shall be a violation for a Participant to violate any SEF Rule or any agreement made with the SEF, or to engage in fraud,

dishonorable or dishonest conduct, or in conduct which is inconsistent with just and equitable principles of trade.

RULE 905 FRAUDULENT ACTS PROHIBITED

No Participant shall engage, or attempt to engage, in any fraudulent act or any scheme to defraud, deceive, trick or mislead in

connection with or related to any SEF Activity.

RULE 906 FICTITIOUS, WASH OR NON-COMPETITIVE TRANSACTIONS PROHIBITED

No Participant shall create, place or accept, or attempt to create, place or accept, fictitious transactions, Wash Transactions, or

non-competitive transactions, except in the case of non-competitive transactions, as otherwise authorized by the SEF Rules, or

execute, or attempt to execute, any such Order if the Participant or any of its Authorized Persons know or should have known that

the transaction is or was a fictitious transaction, Wash Transaction, or non-competitive transaction. No person shall place or

accept, or attempt to place or accept, buy and sell orders in the same Unique Swap Identifier, where the person knows or should

have known that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk. Buy and sell

Orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price

competition shall also be deemed to violate the prohibition on Wash Transactions. Additionally, no Person shall knowingly execute

or accommodate, or attempt to execute or accommodate, the Execution of such Orders by direct or indirect means.
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RULE 907 MARKET DISRUPTION PROHIBITED

Orders entered into the Platform 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 any Participant who makes or assists in entering any

such Order with knowledge of the purpose thereof or who, with such knowledge, in any way assists in carrying out any plan or

scheme for the entering of any such Order, will be deemed to have engaged in an act detrimental to the SEF.

RULE 908 MANIPULATION AND FRAUDULENT CONDUCT PROHIBITED

(a) No Participant shall attempt to manipulate or manipulate the market in any Contract; provided, however, that nothing in this

Rule 908 shall be construed to require any Person to disclose to another Person non-public information that may be material

to the market price, rate, or level of a particular transaction, except as necessary to make any statement made to the other

Person in or in connection with the transaction not misleading in any material respect.

(b) No Participant shall directly or indirectly, in connection with any Contract in interstate commerce, intentionally or recklessly:

(1) Use or employ, or attempt to use or employ, any manipulative device, scheme, or artifice to defraud;

(2) 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;

(3) Engage, or attempt to engage, in any act, practice, or course of business, which operates or would operate as a

fraud or deceit upon any Person; or,

(4) Deliver or cause to be delivered, or attempt to deliver or cause to be delivered, for transmission through the mails or

interstate commerce, by any means of communication whatsoever, a false or misleading or inaccurate report

concerning market information or conditions that affect or tend to affect the price of any Contract in interstate

commerce, knowing, or acting in reckless disregard of the fact that such report is false, misleading or inaccurate;

provided, however, that no violation of this Rule 908 shall exist where the Participant mistakenly transmits, in good

faith, false or misleading or inaccurate information to a price reporting service.

(c) No Participant shall directly or indirectly, manipulate or attempt to manipulate the price of any Swap, or of any Contract in

interstate commerce.

RULE 909 DISRUPTIVE TRADING PRACTICES PROHIBITED

No Participant shall engage in any trading, practice, or conduct that constitutes a “disruptive trading practice,” as such term is

described in Section 4c(a)(5) of the CEA or in interpretive guidance issued by the CFTC.

RULE 910 ABUSIVE TRADING PRACTICES PROHIBITED

No Participant shall engage in any abusive trading practice, including front-running, Wash Transactions, pre-arranged

trading (except with regard to Block Trades), fraudulent trading, fictitious sales, the intentional or reckless disregard for

the orderly execution of transactions during the closing period, the use of swaps to defraud or moneypasses.

RULE 911 PROHIBITION OF MISSTATEMENTS

No Participant shall make any knowing misstatement of a material fact to the SEF, any SEF Official, any Board committee or SEF

panel, or the Regulatory Services Provider.

RULE 912 ACTS DETRIMENTAL TO WELFARE OF THE SEF PROHIBITED

No Participant shall engage in any act that is detrimental to the SEF.

RULE 913 ADHERENCE TO LAW

No Participant shall engage in conduct that is a violation of the CEA or CFTC Regulations.

RULE 914 SUPERVISION
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A Participant shall establish, maintain and administer reasonable supervisory procedures to monitor the compliance of Authorized

Persons with the SEF Rules and any applicable provisions of the CEA or CFTC Regulations, and such Participant may be held

accountable for the actions, failures or omissions of such Authorized Persons.

RULE 915 MISUSE OF THE PLATFORM

Misuse of the Platform is strictly prohibited. It shall be deemed an act detrimental to the SEF to permit unauthorized use of the

Platform, to assist any Person in obtaining unauthorized access to the Platform, to trade on the Platform without a User

Agreement (except for Sponsored Persons), to alter the equipment associated with the Platform (except with the SEF’s consent),

to interfere with the operation of the Platform, to intercept or interfere with information provided thereby, or in any way to use the

Platform in a manner contrary to the SEF Rules.

RULE 916 WITHHOLDING ORDERS PROHIBITED

Any Participant entering Orders on the Platform shall not withhold or withdraw from the market any Order, or any part of an Order,

for the benefit of any Person other than for the Customer for whom the Participant is placing the Order.

RULE 917 PRIORITY OF CUSTOMERS’ ORDERS

No Participant shall enter an Order into the Platform for his own account, an account in which he has a direct or indirect financial

interest or an account over which he has discretionary trading authority, including, without limitation, an Order allowing discretion

as to time and price, when such Participant is in possession of any un-submitted Customer Order based on the same Contract and

with the same fixing date or expiration date and that the Platform is capable of accepting.

RULE 918 HANDLING OF CUSTOMER ORDERS

(a) No Participant in possession of a Customer Order shall knowingly trade ahead of a Customer Order or take, directly or

indirectly, the opposite side of such Order for its own account, an account in which it has a direct or indirect financial interest,

or an account over which it has discretionary trading authority.

(b) No Participant in possession of a Customer Order shall engage in accommodation trading or improper cross-trading.

(c) Exceptions. The restriction in this Rule 918 shall not apply to the following:

(1) Transactions executed pursuant to SEF Rule 602 (Block Trades); or

(2) Transactions executed pursuant to SEF Rule 920 (15 Second Rule).

RULE 919 DISCLOSING ORDERS PROHIBITED

No Participant shall disclose another Customer’s Order to buy or sell except to a designated SEF Official or the CFTC, and no

Participant shall solicit or induce another Participant to disclose Order information. No Person shall take action or direct another to

take action based on non-public Order information, however acquired. The mere statement of opinions or indications of the price at

which a market may open or resume trading does not constitute a violation of this rule.

RULE 920 [RESERVED]

RULE 921 PRE-ARRANGED AND NONCOMPETITIVE TRADES PROHIBITED

(a) No Person shall pre-arrange any purchase or sale or noncompetitively execute any transaction, except in accordance with

Section (b).

(b) The foregoing restriction shall not apply to Transactions executed pursuant to SEF Rule 602 (Block Trades), and, for the

avoidance of doubt, does not prohibit Pre-Execution Communications with respect to RFQ Transactions pursuant to SEF Rule

703 or RFS Transactions pursuant to Rule 704.

RULE 922 RESPONSIBILITY FOR CUSTOMER ORDERS

(a) Standard of Responsibility.

(1) A Participant shall exercise due diligence in the handling and execution of Customer Orders. Failure to act with due
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diligence shall constitute negligence. In the case of a dispute as to whether a Participant has exercised due

diligence, the appropriate arbitration or disciplinary committee is authorized to determine whether the Participant was

negligent and, if so, whether an adjustment is due to the Customer.

(2) A Participant is prohibited from directly or indirectly guaranteeing the execution of an Order or any of its terms such

as the quantity or price. A Participant may only report an execution that has been effected through the Platform or

has been executed under Chapter 7. This Rule 922(a) shall not be construed to prevent a Participant from assuming

or sharing in the losses resulting from an error or the mishandling of an Order provided such action is done in

accordance with the SEF Rules as well as Applicable Law.

(b) Liability for Negligence. A Participant may not be held responsible for executing a Customer Order or failing to execute a

Customer Order unless such Participant was negligent. A Participant may not compel an adjustment from another Participant

in the absence of a bona-fide dispute regarding negligence. Participants shall document all adjustments and shall make and

retain a record which contains the date the adjustment was received, the name of the Participant making the adjustment, the

account to which the adjustment was credited, the amount of the adjustment, the Order number and the reason for the

adjustment. Such records must be provided to the Market Regulation Department upon request.

RULE 923 DISCRETIONARY ORDERS

No Participant shall submit a discretionary order to the Platform for any account of another Person, without the prior specific written

consent of such other Person to the exercise of such discretion.

RULE 924 POSITION LIMITS

(a) To reduce the potential threat of market manipulation or congestion, the SEF shall adopt for each of the Contracts listed on

the Platform, as is necessary and appropriate, position limitations or position accountability levels for speculators.

(b) Except as otherwise provided by these SEF Rules, no Person, including a Participant, may hold or control a position in excess

of such position limits, and a Participant may not maintain a position in excess of such position limits for a Client or Customer

if such Participant knows, or with reasonable care should know, that such position will cause such Client or Customer to

exceed the applicable position limits.

(c) Position limits shall apply to (i) all positions in accounts for which any Person, by power of attorney or otherwise, directly or

indirectly holds positions or controls trading, and (ii) positions held by two or more Persons acting pursuant to an express or

implied agreement or understanding, as if the positions were held by, or the trading of the positions were done by, a single

Person.

RULE 925 EXEMPTIONS FROM POSITION LIMITS

The SEF may grant exemptions from position limits under Rule 924 for bona fide hedging positions and risk management

positions and otherwise on good cause shown and to the extent permitted by Applicable Law. Any Person seeking an exemption

from the position limits referred to in Rule 924 must file an application with the SEF in the manner and within the time limits

prescribed by the SEF. The SEF shall notify the applicant whether the exemption has been approved and whether the SEF has

imposed any limitations or conditions on the exemption. The decision of the SEF shall be final.

RULE 926 POSITION ACCOUNTABILITY

(a) The SEF may establish a position accountability level for any Swap. Any Person, including a Participant, who owns or controls

Swaps in excess of the applicable position accountability level shall provide to the SEF at its request any information

regarding the nature of the position, trading strategy or hedging activities, if applicable, and if ordered by the SEF, shall

liquidate any or all of the positions, or not increase the size of any such position.

(b) For purposes of this Rule, all positions in accounts for which a Person, by power of attorney or otherwise, directly or indirectly

controls trading shall be included with the positions held by such Person. The provisions of this Rule shall apply to positions

held by two or more Persons acting pursuant to an express or implied agreement or understanding, as if the positions were

held by a single Person.

RULE 927 PLATFORM ACCESS RESTRICTIONS

All individuals entering Customer Orders in other than a clerical capacity must have appropriate industry registration. Customer

Orders may be entered only from the premises of an entity registered to conduct Customer business.

RULE 928 PRE-EXECUTION CREDIT CHECKS
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Pre-execution credit checks will be performed for Permitted Transactions executed on the Order Book. If a credit check fails, a

trade is not permitted.

RULE 929 RISK CONTROLS FOR TRADING

(a) The SEF reserves the right to modify, adjust, or cancel any Transaction, including Block Trades, that it determines in its sole

discretion to be unlawful, off market, the result of error, or otherwise incompatible with these SEF Rules, the User Agreement,

or the efficient and secure operation of the SEF, including, but not limited to, excessive electronic traffic sent by any

Participant, to the SEF.

(b) The SEF reserves the right to modify or adjust trade prices, or cancel any Transaction, including Block Trades, when such

action is necessary to mitigate market disrupting events caused by malfunctions in the SEF’s systems or the Platform or

errors in orders submitted by Participants, Clients, Customers or Sponsored Persons.

(c) Notwithstanding any other provisions of this Rule, the SEF may modify or adjust trade prices or cancel any Transaction if the

SEF determines that allowing the Transaction to stand as executed may have a material, adverse effect on the integrity of the

market.

(d) A decision by the SEF pursuant to this Rule 929 to modify or adjust trade prices, or cancel a Transaction, will be made as

soon as practicable, and the SEF shall notify Participants and the Swap Data Repository as soon as practicable: (1) that a

trade is under review; and (2) of the SEF’s final determination with respect to the modification, adjustment or cancellation. In

deciding whether or not to modify or adjust trade prices, or cancel a Transaction, the SEF may consider any information that it

determines to be relevant, including, but not limited to, the last trade price of the Swap, a better bid or offer that was available

on the Platform, the price of the same or related Swap 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 trade, indications of interest, and

responses to an RFQ.

(e) The SEF shall have the right to take any action to reduce the potential of market disruption, including but not limited to,

market restrictions that pause or halt trading in market conditions prescribed by the SEF if such action is in the best interest of

the swap markets.

(f) The SEF sets a default order size limit for all Orders (regardless of currency pair) submitted to the Platform, which the SEF

may adjust from time to time. Participants may set lower limits, which can be established across all currency pairs or for

specific currency pairs.

RULE 930 [RESERVED]

RULE 931 LIMITATION OF LIABILITY, NO WARRANTIES

(a) NEITHER THE SEF (INCLUDING ITS SUBSIDIARIES AND AFFILIATES AND ANY CONTRACTORS PROVIDING

SERVICES TO THE SEF), NOR ANY OF THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS,

CONSULTANTS, AND LICENSORS (THE “DISCLAIMING PARTY” OR “DISCLAIMING PARTIES”) SHALL 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),

ARISING FROM:

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

INTERRUPTION, TERMINATION, OR ANY OTHER EVENT, 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 THE PLATFORM, 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, AND FIRMWARE RELATING THERETO; OR

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

INTERRUPTION OR TERMINATION, OR ANY OTHER EVENT, OF ANY SYSTEM OR SERVICE OF THE SEF, 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 THE SEF OR ANY OF THE SEF’S
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SYSTEMS, SERVICES OR FACILITIES; OR

(4) ANY UNAUTHORIZED ACCESS TO OR UNAUTHORIZED USE OF ANY OF THE SEF’S SYSTEMS, SERVICES,

EQUIPMENT OR FACILITIES BY ANY PERSON.

THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY WHETHER A CLAIM ARISES IN CONTRACT, TORT,

NEGLIGENCE, STRICT LIABILITY, CONTRIBUTION OR OTHERWISE AND WHETHER THE CLAIM IS BROUGHT

DIRECTLY OR AS A THIRD PARTY CLAIM. THE FOREGOING LIMITATION OF LIABILITY SHALL NOT APPLY TO ANY

LIABILITIES ARISING OUT OF A VIOLATION BY THE SEF OF THE CEA AND/OR CFTC REGULATIONS, INCLUDING

PART 37 OF THE CFTC’S REGULATIONS. THE LIMITATION OF LIABILITY CONTAINED IN SUBSECTION (a) OF THIS

RULE 931 SHALL NOT APPLY TO THE SEF IN INSTANCES WHERE A DISCLAIMING PARTY HAS BEEN FINALLY

ADJUDICATED TO HAVE ENGAGED IN GROSS NEGLIGENCE OR WILLFUL OR WANTON MISCONDUCT.

(b) NOTWITHSTANDING SUBSECTION (a), (e), OR (f) OF THIS RULE 931, IN NO EVENT SHALL ANY PERSON BRING ANY

LEGAL ACTION (WHETHER IN TORT, NEGLIGENCE, OR BREACH OF CONTRACT) FOR ANY LOSSES DAMAGES,

COSTS OR EXPENSES INCLUDING, BUT NOT LIMITED TO LOSS OF PROFITS, LOSS OF USE, DIRECT, SPECIAL,

PUNITIVE, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES, ARISING FROM THE USE OF THEPLATFORM.

(c) THERE ARE NO EXPRESS OR IMPLIED WARRANTIES OR REPRESENTATIONS (INCLUDING BUT NOT LIMITED TO

WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE OR USE) PROVIDED BY THE

DISCLAIMING PARTY OR DISCLAIMING PARTIES RELATING TO ANY SYSTEMS OR SERVICES OF THE SEF OR

SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH SYSTEMS OR SERVICES, INCLUDING THE SEF

PLATFORM.

(d) ANY DISPUTE ARISING OUT OF THE USE OF SYSTEMS OR SERVICES OF THE SEF OR SERVICES, EQUIPMENT, OR

FACILITIES USED TO SUPPORT SUCH SYSTEMS OR SERVICES IN WHICH THE DISCLAIMING PARTY OR

DISCLAIMING PARTIES IS A PARTY SHALL BE ARBITRATED PURSUANT TO CHAPTER 11. ANY ARBITRATION SHALL

BE BROUGHT WITHIN THE PERIOD PRESCRIBED BY CHAPTER 11. ANY OTHER ACTIONS, SUITS OR

PROCEEDINGS AGAINST THE DISCLAIMING PARTY OR DISCLAIMING PARTIES MUST BE BROUGHT WITHIN TWO (2)

YEARS FROM THE TIME THAT A CAUSE OF ACTION HAS ACCRUED. THIS PARAGRAPH (d) SHALL IN NO WAY BE

CONSTRUED TO LIMIT A PARTY’S OBLIGATION TO ARBITRATE ITS CLAIM OR TO CREATE A CAUSE OF ACTION AND

SHALL NOT AUTHORIZE AN ACTION THAT WOULD OTHERWISE BE PROHIBITED BY THE SEF RULES. IF FOR ANY

REASON, A COURT OF COMPETENT JURISDICTION FINDS THAT A DISPUTE IS NOT ARBITRABLE, SUCH DISPUTE

MAY ONLY BE LITIGATED IN THE COUNTY OF NEW YORK IN THE STATE OF NEW YORK AND WILL BE GOVERNED

BY THE LAWS OF THE STATE OF NEW YORK WITHOUT REGARD TO ANY PROVISIONS OF NEW YORK LAW THAT

WOULD APPLY THE SUBSTANTIVE LAW OF A DIFFERENT JURISDICTION.

(e) THE SEF MAY, IN ITS SOLE DISCRETION, ASSUME RESPONSIBILITY FOR DIRECT, OUT-OF-POCKET LOSSES

DIRECTLY CAUSED BY THE NEGLIGENCE OF A DISCLAIMING PARTY OR PARTIES AND/OR ORDER STATUS

ERRORS PROVIDED BY THE SEF OR A SEF SYSTEM, EQUIPMENT, SERVICE OR FACILITY. NOTWITHSTANDING

THE ABOVE, i) THE SEF’S TOTAL COMBINED AGGREGATE OBLIGATIONS SHALL NOT EXCEED $10,000 FOR ALL

LOSSES FROM ALL CAUSES SUFFERED ON A SINGLE DAY; $25,000 FOR ALL LOSSES SUFFERED FROM ALL

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

SINGLE CALENDAR YEAR. ANY DISPUTED CLAIM PURSUANT TO THIS PARAGRAPH (e) MUST BE ARBITRATED

PURSUANT TO CHAPTER 11.

(f) IN NO EVENT SHALL THE SEF’S TOTAL COMBINED AGGREGATE LIABILITY FOR ALL CLAIMS ARISING OUT OF ANY

FAILURES, MALFUNCTIONS, FAULTS IN DELIVERY, DELAYS, OMISSIONS, SUSPENSIONS, INACCURACIES,

INTERRUPTIONS, TERMINATIONS, 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 THE

SEF’S SYSTEMS OR SERVICES, OR SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH SYSTEMS

AND SERVICES, OR THE NEGLIGENCE OF THE SEF STAFF EXCEED $500,000 IN ANY GIVEN CALENDAR YEAR. IF

THE NUMBER OF ALLOWED CLAIMS ARISING OUT OF ANY FAILURES OR MALFUNCTIONS ON A SINGLE DAY OR

SINGLE MONTH CANNOT BE FULLY SATISFIED BECAUSE OF THE ABOVE DOLLAR LIMITATIONS, ALL SUCH CLAIMS

SHALL BE LIMITED TO A PRO RATA SHARE OF THE MAXIMUM AMOUNT FOR THE RESPECTIVE PERIOD.

Chapter 10 – Disciplinary Rules
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RULE 1001 GENERAL

(a) All Participants, Account Managers, Authorized Persons, Authorized Representatives, Clients, Customers and Sponsored

Persons (collectively “SEF Market Participants”) shall be subject to the SEF’s jurisdiction. All SEF Market Participants are

subject to this Chapter 10 if they, or with respect to a Participant, any other Person using its Legal Entity Identifier or CICI, are

alleged to have violated, to have aided and abetted a violation, to be violating, or to be about to violate, any SEF Rule or any

provision of Applicable Law for which the SEF possesses disciplinary jurisdiction.

(b) The Market Regulation Department has the authority to: (i) initiate and conduct inquiries and investigations; (ii) prepare

investigative reports and make recommendations concerning initiating disciplinary proceedings; and (iii) prosecute alleged

violations within the SEF’s disciplinary jurisdiction.

(c) Each SEF Market Participant: (i) is obligated to appear and testify and respond in writing to interrogatories within the time

period required by the Market Regulation Department in connection with: (A) any Obligation; (B) any inquiry or investigation; or

(C) any preparation by and presentation during a Disciplinary Action; (ii) is obligated to produce all books, records, papers,

documents or other tangible evidence in its, his or her possession, custody or control within the time period required by the

Market Regulation Department in connection with: (A) any Obligation; (B) any inquiry or investigation; or (C) any preparation

by and presentation during a Disciplinary Action; and (iii) may not impede or delay any DisciplinaryAction.

(d) The SEF, through the Market Regulation Department, will promptly prosecute possible rule violations within the SEF’s

disciplinary jurisdiction.

(e) The SEF, through the Regulatory Services Provider, if any, and the Disciplinary Panel, will conduct inquiries, investigations,

disciplinary proceedings, summary impositions of fines, summary suspensions or other summary actions in accordance with

this Chapter 10.

(f) No SEF Official or Officer will interfere with or attempt to influence the process or resolution of any inquiry, investigation, or

disciplinary proceeding. No Director will interfere with or attempt to influence the process or resolution of any Disciplinary

Action except to the extent provided under the SEF Rules.

(g) Any SEF Market Participant may be represented by counsel during any inquiry, investigation, disciplinary or appeals

proceeding, summary imposition of fines, summary suspension or other summary actions pursuant to this Chapter 10.

(h) Participant Liability – Individual and Joint Liability/Controlling Person Liability.

(1) The SEF may hold a Participant liable for, and impose sanctions against such Participant, for such Participant’s own

acts and omissions that constitute a violation as well as for the acts and omissions of each (A) Authorized Person

authorized by such Participant, (B) other Person using a Legal Entity Identifier or CICI of such Participant or (C) other

agent or representative of such Participant, in each case, that constitute a violation as if such violation were that of

the Participant.

(2) The SEF may hold an Authorized Person liable for, and impose sanctions against such Authorized Person for such

Authorized Person’s own acts and omissions that constitute a violation as well as or for the acts and omissions of

any other agent or representative of such Authorized Person that constitute a violation as if such violation were that

of the Authorized Person.

(3) [Reserved]

(i) Ex Parte Communications.

(1) A Person subject to a disciplinary proceeding (and any counsel or representative of such Person) and the Market

Regulation Department (and any counsel or representative of the Market Regulation Department) shall not knowingly

make or cause to be made an ex parte communication relevant to the merits of a disciplinary proceeding to any

member of the Disciplinary Panel hearing such proceeding.

(2) Members of a Disciplinary Panel shall not knowingly make or cause to be made an ex parte communication relevant

to the merits of a disciplinary proceeding to any Person subject to such proceeding (and any counsel or

representative of such Person) and the Market Regulation Department (and any counsel or representative of the

Market Regulation Department).
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(3) Any Person who receives, makes or learns of any communication that is prohibited by this rule shall promptly give

notice of such communication and any response thereto to the Market Regulation Department and all parties to the

proceeding to which the communication relates.

(4) A Person shall not be deemed to have violated this rule if the Person refuses an attempted communication

concerning the merits of a proceeding as soon as it becomes apparent the communication concerns the merits.

RULE 1002 INVESTIGATIONS AND INVESTIGATION REPORTS

(a) Procedures.

(1) The SEF’s Market Regulation Department shall initiate an investigation upon the receipt of a request from the CFTC

or upon the discovery or receipt of information that, in the judgment of the Market Regulation Department, indicates a

possible basis for finding that a violation has occurred or will occur.

(2) Absent mitigating circumstances, a Market Regulation Department investigation must be completed no later than

twelve (12) months after the date that such investigation is opened. If a Market Regulation Department investigation

will take longer than twelve (12) months to complete, the Market Regulation Department must explain the reasons in

writing to the Chief Compliance Officer.

(b) Investigation Reports.

(1) If the Market Regulation Department determines that a reasonable basis exists for finding a violation of the SEF

Rules or Applicable Law, the Market Regulation Department must submit a written report to the Review Panel, which

shall include: all relevant facts and evidence gathered; a summary of the reason the investigation was initiated; a

summary of the complaint, if any; a description of the SEF Market Participant’s disciplinary history (including warning

letter); the Market Regulation Department’s analysis and conclusions; and a recommendation as to whether

Disciplinary Action should be pursued.

(2) If the Market Regulation Department determines that no reasonable basis exists for finding a violation of the SEF

Rules or Applicable Law, the Market Regulation Department must nonetheless submit a written report to the Chief

Compliance Officer, which shall include: the reason the investigation was initiated; a summary of the complaint, if

any; the relevant facts; Market Regulation Department’s analysis and conclusions; and if applicable, any

recommendation that a disciplinary committee issue a warning letter. If the Market Regulation Department

recommends that a warning letter be issued to a SEF Market Participant, the investigation report shall include a copy

of the letter as well as the SEF Market Participant’s disciplinary history at the SEF, including copies of warning letters.

(c) Warning Letters.

(1) After conducting an investigation pursuant to Rule 1002(a), the Market Regulation Department may recommend to

the Chief Compliance Officer that the SEF issue a warning letter to a SEF Market Participant. Upon such

recommendation, the Chief Compliance Officer may issue a warning letter to any SEF Market Participant. A warning

letter is not a penalty or an indication that a finding of a violation has been made. No more than one warning letter

may be issued per rolling 12-month period for the same violation by the same Person.

RULE 1003 DISCIPLINARY PANELS

(a) Disciplinary Panel Composition.

(1) The SEF, through the Regulatory Services Provider, if any, shall have a Review Panel and a Hearing Panel

(collectively, the “Disciplinary Panel”).

(2) Each Disciplinary Panel shall consist of no fewer than three members, who shall be appointed by the Chief

Compliance Officer or the Regulatory Services Provider, if any. Each Disciplinary Panel shall represent the interests

of a diversity of Participants so as to ensure fairness and to prevent special treatment or preference for any Person

in the conduct of the Disciplinary Panel's responsibilities, and shall consist of at least one individual who is not an

employee of the SEF, a member of the Regulatory Services Provider, an employee of a member of the Regulatory

Services Provider, or an employee of the Regulatory Services Provider. No member of the Market Regulation

Department or Person involved in adjudicating any other stage of a proceeding shall participate in a Disciplinary

Panel for such proceeding. Additionally, a Disciplinary Panel shall consist of at least one individual who is not a

Participant or an employee of a Participant with respect to any disciplinary action in which the subject of the action is

a member of the Board or the Disciplinary Panel, or for any disciplinary action in which any of the charged, alleged or
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adjudicated violations involve manipulation or attempted manipulation of the price of a Contract, or conduct which

directly results in financial harm to a Person that is not a Participant of the SEF.

(3) All information, records, materials and documents provided to the Disciplinary Panels and all deliberations,

testimony, information, records, materials and documents related thereto shall be treated as non-public and

confidential and shall not be disclosed, except as necessary to further an investigation or as required by law.

(b) Review Panel. The Review Panel is responsible for determining whether a reasonable basis exists for finding a violation of the

SEF Rules, and for authorizing the issuance of notices of charges against Persons alleged to have committed violations if the

Review Panel believes that the matter should be adjudicated. No member of a Review Panel may have a financial, personal,

or other direct interest in the matter under consideration, or a material conflict of interest (as described in Rule 210) with the

Person alleged to have committed violations, any potential party to the proceeding, or a Person known by the member to be

an employer, employee, or co-worker of the Person alleged to have committed violations or a potential party to the proceeding.

(c) Hearing Panel. The Hearing Panel is responsible for adjudicating disciplinary cases pursuant to a notice of charges

authorized by a Review Panel. No member of a Hearing Panel may have a financial, personal, or other direct interest in the

matter under consideration, or a material conflict of interest (as described in Rule 210) with the respondent, any party to the

proceeding, a witness or Person that the Hearing Panel reasonably believes will be a witness (a “potential witness”), or a

Person known by the member to be an employer, employee, or co-worker of the respondent, a party, or a witness or potential

witness.

RULE 1004 REVIEW OF INVESTIGATORY REPORT

(a) Within thirty (30) days of receiving a completed investigation report pursuant to Rule 1002, a Review Panel must take one of

the following actions:

(1) If the Review Panel determines that additional investigation or evidence is needed, it must promptly direct the Market

Regulation Department 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.

(3) If the Review Panel determines that a reasonable basis exists for finding a violation and adjudication is warranted, it

must direct that the person or entity alleged to have committed the violation be served with a notice of charges and

must proceed in accordance with the rules of this section.

RULE 1005 NOTICE OF CHARGES

(a) If the Review Panel directs that a respondent be served with a notice of charges pursuant to Rule 1004(a)(3), the Market

Regulation Department shall prepare and serve a notice of charges.

(b) A notice of charges will state the acts, conduct, or practices in which the respondent is alleged to have engaged; state the

rule, or rules, alleged to have been violated (or about to be violated); advise the respondent that he is entitled, upon request,

to a hearing; prescribe the period within which a hearing on the charges may be requested, which shall not be less than

twenty

(20) days; advise the respondent that he has the right to be represented by legal counsel or any other representative of its

choosing in all succeeding stages of the disciplinary process; advise the respondent that any failure to request a hearing

within the period stated, except for good cause, will be deemed to constitute a waiver of the right to a hearing; and advise the

respondent that any allegation in the notice of charges that is not expressly denied will be deemed to be admitted.

(c) Any notice of charges or other documents to be served pursuant to this Chapter 9 may be served upon the respondent and

service shall be deemed complete either personally or by leaving the same at his or her place of business; by deposit in the

United States mail, postage prepaid, via registered or certified mail addressed to the respondent at the address as it appears

on the books and records of the SEF; or via electronic mail to the electronic mail address as it appears on the books and

records of the SEF.

(d) Upon being served with a notice of charges, a respondent will have the right to be represented by legal counsel or any other

representative of its choosing in all succeeding stages of the disciplinary process.

RULE 1006 ANSWER TO NOTICE OF CHARGES

(a) In General. If the respondent determines to answer a notice of charges, the respondent must, in writing:
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(1) specify the allegations that the respondent denies or admits;

(2) specify the allegations that the respondent does not have sufficient information to either deny or admit;

(3) specify any specific facts that contradict the notice of charges;

(4) specify any affirmative defenses to the notice of charges; and

(5) sign and serve the answer on the Chief Compliance Officer.

(b) Failure to Respond.

(1) Any failure by the respondent to timely serve an answer to a notice of charges will be deemed to be an admission to

the allegations in such notice. Any failure by the respondent to answer one or more allegations in a notice of charges

will be deemed to be an admission of that allegation or those allegations. Any allegation in a notice of charges that

the respondent fails to expressly deny will be deemed to be admitted. A general denial by the respondent, without

more, will not satisfy the requirements of paragraph (a) above.

(2) If a respondent admits to allegations through such a failure to respond, the Hearing Panel shall impose appropriate

sanctions.

(3) Before imposing sanctions pursuant to Rule 1006(b)(2), the Hearing Panel will notify the respondent in writing of any

sanction to be imposed and advise the respondent that it may request a hearing on such sanction within a specified

period of time. If a respondent fails to request a hearing within twenty (20) days after being served with such notice,

the respondent will be deemed to have accepted the sanction.

(c) Denial of Charges and Right to Hearing.

(1) If a respondent requests a hearing on a charge that is denied pursuant to Rule 1006(a), or on a sanction set by the

Hearing Panel pursuant to Rule 1006(b)(3), the respondent shall be entitled to a hearing in accordance with Rule

1009.

(2) Except for good cause shown, the hearing will be concerned only with those charges denied and/or sanctions set by

the Hearing Panel under Rule 1006(b)(3) for which a hearing has been requested.

RULE 1007 SETTLEMENTS

(a) A respondent or potential respondent may at any time propose in writing an offer of settlement related to anticipated or

instituted disciplinary proceedings.

(b) Any offer of settlement should contain proposed findings and sanctions and be signed by the respondent or potential

respondent and submitted to the Disciplinary Panel presiding over the matter.

(c) A respondent or potential respondent may offer to settle disciplinary proceedings without admitting or denying the findings

contained in the order of the disciplinary proceedings but must accept the jurisdiction of the SEF over it and over the subject

matter of the proceedings and consent to the entry of the findings and sanctions imposed.

(d) If a respondent or potential respondent submits an offer of settlement in accordance with paragraph (a) above, the Market

Regulation Department will forward the offer to the Hearing Panel with a recommendation on whether to accept or reject the

offer. If the Market Regulation Department and Hearing Panel agree to accept the offer of settlement, then the offer of

settlement shall be accepted. If applicable, the Hearing Panel’s decision must include a statement that the respondent has

accepted the sanctions imposed without either admitting or denying the rule violations.

(e) Upon accepting any offer of settlement, the Hearing Panel shall issue a written decision specifying the rule violations it has

reason to believe were committed, including the basis or reasons for the panel’s conclusions, and any sanction to be

imposed, which must include full customer restitution where customer harm is demonstrated.

(f) If an offer of settlement is accepted by the Hearing Panel, the respondent’s submission of the offer will be deemed to

constitute a waiver of the right to notice, opportunity for a hearing and review and appeal under the SEF Rules.
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(g) If the offer of settlement is not accepted or is withdrawn by the respondent or potential respondent, the matter will proceed as

if the offer had not been made and the offer and all documents relating to it will not become part of the record. Neither a

respondent or potential respondent nor the Hearing Panel may use an unaccepted offer of settlement as an admission or in

any other manner at a hearing of, or appeal from, disciplinary proceedings.

RULE 1008 RESPONDENT REVIEW OF EVIDENCE

(a) Prior to the commencement of a hearing, each respondent will be given the opportunity to review all books, records,

documents, papers, transcripts of testimony and other tangible evidence in the possession or under the control of the SEF

that the Market Regulation Department will use to support the allegations and proposed sanctions in the notice of charges or

which the chair of the Hearing Panel deems relevant to the disciplinary proceedings. Notwithstanding the foregoing, no

respondent will have the right to review, and the SEF will have no obligation to disclose, any information protected by

attorney-client privilege.

(b) If any books, records, documents, papers, transcripts of testimony, or other tangible evidence contain information that could

adversely affect the competitive position of the Person providing the information or if such information might compromise

other investigations being conducted by the Market Regulation Department, the Market Regulation Department may redact,

edit or code such information before furnishing it to the respondent.

(c) Notwithstanding anything in paragraph (b) above to the contrary, the Market Regulation Department:

(1) will not redact, edit or code competitive or investigative information contained in documents in a manner that would

impair the respondent’s ability to defend against the allegations or proposed sanctions in the notices of charges; and

(2) will provide the respondent with access to the information and portions of the documents that the Market Regulation

Department intends to rely on to support the allegations or proposed sanctions in the notice of charges.

(d) For purposes of this Rule 1008, information that could adversely affect competitive positions include positions in Contracts

currently held, trading strategies employed in establishing or liquidating positions, the identity of any SEF Market Participant,

and the personal finances of the Person providing the information.

RULE 1009 HEARINGS

Hearings shall be conducted pursuant to the procedures below.

(a) Hearing Procedures

(1) A hearing shall be fair, shall be conducted before members of the disciplinary panel, and shall be promptly convened

after reasonable notice to the respondent.

(2) If the respondent has requested a hearing, a copy of the hearing shall be made and shall become a part of the

record of the proceeding. The record shall not be required to be transcribed unless:

i. The transcript is requested by CFTC staff or the respondent; or

ii. The decision is reviewed by the CFTC.

In all other instances, a summary record of a hearing will be prepared.

(3) After reasonable notice to each respondent, the Hearing Panel will promptly convene a hearing to conduct the

disciplinary proceedings with respect to such respondent. Parties to a disciplinary proceeding include each

respondent and the Market Regulation Department.

(4) The chair of the Hearing Panel may continue, adjourn or otherwise conduct the hearing, as he or she may deem

appropriate. The chair of the Hearing Panel will determine all procedural and evidentiary matters, including the

admissibility and relevance of any evidence proffered. In determining procedural and evidentiary matters, the chair of

the Hearing Panel will not be bound by any evidentiary or procedural rules or law. Once admitted during the hearing,

the Hearing Panel may consider, and attach the weight it believes appropriate to, evidence or other materials.

(5) Except for procedural and evidentiary matters decided by the chair of the Hearing Panel pursuant to paragraph (3),

unless each respondent otherwise consents, the entire Hearing Panel must be present during the entire hearing and
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any related deliberations.

(b) Conducting Hearings.

(1) At a hearing conducted in connection with any disciplinary proceedings, the Market Regulation Department will

present its case supporting the allegations and proposed sanctions in the notice of charges to the Hearing Panel. If a

respondent has timely filed an answer to the notice of charges in accordance with Rule 1006, the respondent is

entitled to attend and participate in the hearing.

(2) At a hearing conducted in connection with any disciplinary proceedings, the Hearing Panel or the Market Regulation

Department and each respondent may:

i. present evidence and facts determined relevant and admissible by the chair of the Hearing Panel;

ii. call and examine witnesses; and

iii. cross-examine witnesses called by other parties.

(3) If the respondent fails to file an answer, has filed a general denial, or if any or all of the allegations in the notice of

charges are not expressly denied in the respondent’s answer, the chair of the Hearing Panel may limit evidence

concerning any allegations not expressly denied in determining the sanctions to impose. If a respondent fails to file

an answer but appears at the hearing, the respondent may not participate in the hearing (by calling or crossexamining witnesses, testifying in defense, presenting evidence concerning the notice of charges, or otherwise)

unless the Hearing Panel determines that the respondent had a compelling reason for failing to timely file an answer.

If the Hearing Panel determines that the respondent had a compelling reason for failing to timely file an answer, the

Hearing Panel will adjourn the hearing and direct the respondent to promptly file a written answer in accordance with

Rule 1006.

(4) Any Person entitled, or required or called upon, to attend a hearing before a Hearing Panel pursuant to paragraph

(b)(2) above will be given reasonable notice, confirmed in writing, specifying the date, time and place of the hearing,

and the caption of the disciplinary proceedings. All SEF Market Participants (that are individuals) that are called as

witnesses are required to appear at the hearing and, where applicable, produce evidence. The Market Regulation

Department will make reasonable efforts to secure the presence of all other Persons called as witnesses whose

testimony would be relevant.

(5) If during any disciplinary proceeding, the Hearing Panel determines that a reasonable basis exists to believe that the

respondent violated or is about to violate a Rule of the SEF or a provision of Applicable Law other than the violations

alleged in the notice of charges, the Hearing Panel may consider those apparent violations after providing the

respondent with an opportunity to answer the additional allegations in accordance with Rule 1006. In connection with

considering apparent violations pursuant to this paragraph (b)(5), the Hearing Panel may request that the Market

Regulation Department provide the Hearing Panel with any additional information related to the violations at issue.

(6) The SEF will arrange for an audio recording of every hearing conducted in connection with disciplinary proceedings

to be created, which shall become a part of the record. At the direction of the CFTC or the request of the respondent,

the SEF will arrange for the recording to be accurately transcribed. If the respondent requests a copy of all or

portions of the recording of a hearing, the chair of the Hearing Panel may within his or her sole discretion require the

respondent to pay the costs for transcribing the recording of the hearing.

(c) The Hearing Panel may summarily impose sanctions on any SEF Market Participant that impedes or delays the progress of a

hearing.

(d) No interlocutory appeals of rulings of any Hearing Panel or chair of the Hearing Panel are permitted.

RULE 1010 DECISION OF HEARING PANEL

The decision of the Hearing Panel shall be made pursuant to the procedures of the Regulatory Services Provider, if any, or

through the procedures below.

(a) As promptly as reasonable following a hearing, the Hearing Panel will issue a written order rendering its decision based on

the weight of the evidence contained in the record of the disciplinary proceedings. A decision by a majority of the Hearing

Panel will constitute the decision of the Hearing Panel.
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(b) The Chief Compliance Officer will serve a copy of the order of the disciplinary proceedings on the respondent and the Market

Regulation Department. The order will include:

(1) the notice of charges or summary of the allegations;

(2) the answer, if any, or a summary of the answer;

(3) a brief summary of the evidence introduced at the hearing or, where appropriate, incorporation by reference of the

Investigation Report;

(4) findings of fact and conclusions concerning each allegation, including a complete explanation of the evidentiary and

other basis for such findings and conclusions with respect to each allegation;

(5) each specific Rule of the SEF and provision of Applicable Law that the respondent is found to have violated; and

(6) the imposition of sanctions, if any, including the basis for such sanctions and the effective date of each sanction.

(c) The decision of a Hearing Panel will not become effective until at least 15 days after the written notice described in Rule

1010(b) is served on the respondent and a copy thereof is provided to the Market Regulation Department, except as provided

for in CFTC Regulation 9.12.

RULE 1011 SANCTIONS

(a) After notice and opportunity for hearing in accordance with the SEF Rules, the SEF will impose sanctions if any SEF Market

Participant or other Person using the Participant’s Legal Entity Identifier or CICI is found to have violated or to have attempted

to violate a Rule of the SEF or provision of Applicable Law for which the SEF possesses disciplinary jurisdiction. All sanctions,

including sanctions imposed pursuant to an accepted settlement offer, shall be commensurate with the violations committed

and shall be sufficient to deter recidivism or similar violations by other market participants, and must take into account the

respondent’s disciplinary history. In the event of demonstrated customer harm, any sanction must also include full customer

restitution, except where the amount of restitution or to whom it should be provided cannot be reasonably determined. The

SEF may impose one or more of the following sanctions or remedies: (1) censure; (2) limitation on Trading Privileges, ability

to otherwise access the Platform, and/or other activities, functions or operations; (3) suspension of Trading Privileges and/or

ability to otherwise access the Platform; (4) fine (subject to paragraph (b) below); (5) restitution or disgorgement; (6)

termination of Trading Privileges and/or ability to otherwise access the Platform; or (7) any other sanction or remedy deemed

to be appropriate.

(b) The SEF may impose a fine for each violation of a Rule of the SEF or a provision of Applicable Law. If a fine or other amount

is not paid within 30 days of the date that it becomes payable, then interest will accrue on the sum from the date that it

became payable at the quoted prime rate plus three (3) percent. The SEF has sole discretion to select the bank on whose

quotations to base the prime rate. Participant will be responsible for paying any fine or other amount imposed on, but not paid

by, any of its Authorized Persons or Authorized Representatives.

RULE 1012 RIGHT TO APPEAL

An appeal of a suspension, expulsion, disciplinary or access denial action, or other adverse action, including summary actions (as

such terms are defined in CFTC Regulation 9.2 as applicable), imposed by the SEF pursuant to the SEF Rules may be taken

pursuant to Part 9 of the CFTC Regulations.

RULE 1013 SUMMARY FINES

(a) The Chief Compliance Officer or Market Regulation Department may summarily impose a fine for violations of rules relating to:

(1) the timely submission of accurate records required for clearing or verifying each day’s transactions;

(2) the timely payments of dues, assessments, fees, costs, charges, fines or arbitration awards to the SEF, or customer

restitution ordered by the SEF;

(3) the timely and accurate submissions to the SEF of notices, reports or other information required by the SEF Rules;

or,

(4) the maintenance of any books and records required by the SEF Rules.
(b) The Chief Compliance Officer or Market Regulation Department will give notice of any summary fine imposed pursuant to this

Rule 1013 to each Participant subject thereto. Such notice shall include:

(1) the violations of the SEF Rules for which the fine is being imposed;

(2) the date of the violation for which the fine is being imposed; and,

(3) the amount of the fine.

(c) In lieu of a summary fine, the Chief Compliance Officer may issue a warning letter for first-time violations or violators pursuant

to Rule 1002(c), provided that no more than one warning letter may be issued per rolling 12-month period for the same

violation by the same Person.

(d) Any Person subject to a summary fine may challenge such summary fine by denying the charges and filing a request for a

hearing pursuant to Rule 1006(c).

(e) The SEF will set the amount of any fines imposed pursuant to this Rule 1013, with the maximum fine for each violation not to

exceed $3,000. Summary imposition of fines pursuant to this Rule 1013 will not preclude the SEF from bringing any other

action against the Participant (or any of its Account Managers, Authorized Persons or Authorized Representatives). The

following schedule lists the recommended summary fines that the Chief Compliance Officer or Market Regulation Department

may impose:

Type of Violation Fine Per Occurrence (within a

“rolling” 12-month period)

First

Violation

Second

Violation

Third

Violation

Violations of rules relating to the timely submission of

accurate records required for clearing or verifying

each day’s transactions

$1000 $1,250 $2,000

Violations of rules relating to the timely payments of

dues, assessments, fees, costs, charges, fines or

arbitration awards to the SEF, or customer restitution

ordered by the SEF

$1000 $1,250 $2,000

Violations of rules relating to the timely and

accurate submissions to the SEF of notices, reports

or other information required by the SEF Rules

$1000 $1,250 $2,000

Violations of rules relating to the maintenance of

any books and records required by the SEF Rules

$1000 $1,250 $2,000

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RULE 1014 EMERGENCY SUMMARY SUSPENSIONS AND OTHER SUMMARY ACTIONS

(a) Notwithstanding anything in the SEF Rules to the contrary, the Chief Compliance Officer may, after consultation with the

Market Regulation Department, if practicable, summarily suspend, revoke, limit, condition, restrict or qualify a SEF Market

Participant’s Trading Privileges and/or ability to otherwise access the Platform; provided, however, that the Chief Compliance

Officer may only summarily suspend a SEF Market Participant’s Trading Privileges or the trading privileges of any

Participant’s Authorized Persons if the Chief Compliance Officer reasonably believes that:

(1) such Person is subject to statutory disqualification from registration as provided in CEA Section 8a(2) or(3);

(2) such Person has failed to pay applicable dues, assessments, fees, costs, charges, fines or arbitration awards to the

SEF, or customer restitution ordered by the SEF; or
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(3) immediate action is necessary to protect the public or the best interests of the SEF. and

provided further that any decision to summarily suspend, revoke, limit, condition, restrict or qualify a SEF Market Participant’s

Trading Privileges and/or ability to otherwise access the Platform shall be impartially enforced.

(b) Whenever practicable, the SEF shall provide prior written notice to the party against whom any action in accordance with

paragraph (a) shall be taken. If prior notice is not practicable, the SEF will give notice at the earliest possible opportunity to

the respondent against whom the action is brought.

(c) Any action taken in accordance with paragraph (a) will become final upon the expiration of 20 days after the notice of action is

served on the respondent.

(d) At the request of the SEF, a respondent against whom a summary action is brought pursuant to this Rule 1014 must provide

books and records over which the respondent has access or control and must furnish information to, or appear or testify

before, the SEF in connection with the enforcement of any Rule of the SEF.

RULE 1015 RIGHTS AND RESPONSIBILITIES AFTER SUSPENSION OR TERMINATION

(a) When a SEF Market Participant’s Trading Privileges and/or ability to otherwise access the Platform are suspended for a

period of 12 months or less, none of its rights (including the right to hold oneself out to the public as a Participant, enter

Orders into the Platform and receive Participant rates for fees, costs, and charges and deposit margin at Participant levels)

will apply during the period of the suspension, except for the right of the Participant in question to assert claims against others

as provided in the SEF Rules. Any such suspension will not affect the rights of creditors under the SEF Rules or relieve the

SEF Market Participant in question of its, his or her obligations under the SEF Rules to perform any Contracts entered into

before the suspension, or for any the SEF fees, costs, or charges incurred during the suspension. The SEF may discipline a

suspended SEF Market Participant under this Chapter 10 for any violation of a Rule of the SEF or provision of Applicable Law

committed by the SEF Market Participant before, during or after the suspension.

(b) When a Participant’s Trading Privileges and/or ability to otherwise access the Platform are terminated, all of its related rights

will terminate, except for the right of the Participant in question to assert claims against others, as provided in the SEF Rules.

Any such termination will not affect the rights of creditors under the SEF Rules. A terminated Participant may only seek to be

reinstated by applying for Trading Privileges pursuant to Rule 302.

(c) The SEF will not consider the application of a terminated Participant if such Participant, as the case may be, continues to fail

to appear at disciplinary proceedings without good cause or continues to impede the progress of disciplinary proceedings.

(d) A suspended or terminated SEF Market Participant remains subject to the SEF Rules and the jurisdiction of the SEF for acts

and omissions prior to the suspension of termination, and must cooperate in any inquiry, investigation, disciplinary

proceeding, summary suspension or other summary action as if the suspended or terminated SEF Market Participant still had

Trading Privileges or ability to otherwise access the Platform.

(e) In the event of the suspension or revocation of a Participant’s Trading Privileges and/or ability to otherwise access the

Platform, the SEF shall seek to facilitate the transfer of any Customer Accounts held by such Participant to other Participants

with Trading Privileges and/or ability to otherwise access the Platform.

RULE 1016 NOTICE TO THE RESPONDENT, THE REGULATORY SERVICES PROVIDER AND THE PUBLIC

(a) The SEF will provide written notice of disciplinary proceedings to the parties, the Regulatory Services Provider, and the CFTC

to the extent such notice is required by the Regulatory Services Provider and/or the CFTC. Whenever a SEF decision,

pursuant to which a disciplinary action or access denial action is to be imposed becomes final, the SEF shall, within thirty

days thereafter, provide written notice of such action to the Person against whom the action was taken and to the CFTC

pursuant to CFTC Regulation 9.11 in accordance with procedures established by the CFTC.

(b) Any disciplinary or access denial action taken by the SEF will not become effective until at least 15 days after the written

notice described in Rule 1016(a) is delivered to the Person disciplined or denied access, except as provided for in CFTC

Regulation 9.12.

Chapter 11 – Arbitration Rules
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RULE 1101 DISPUTES SUBJECT TO ARBITRATION

(a) Mandatory Arbitration of Disputes.
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(1) It is contrary to the objectives and policy of the SEF for Participants to litigate SEF-related disputes. Participants

must arbitrate all disputes between or among themselves, or against the SEF, that relate to or arise out of any

transaction on or subject to the SEF Rules that are based upon facts and circumstances that occurred at a time

when the parties were Participants. Such arbitrations will be conducted pursuant to the NFA ArbitrationProgram.

(2) Notwithstanding the foregoing, this Rule 1101 does not require an employee of a Participant to submit to arbitration

any claim that includes allegations of a violation of federal, state or local employment discrimination, sexual

harassment, wage payment or benefits laws.

(b) [Reserved]

(c) Permissive Arbitrations.

The following may be submitted for arbitration through the National Futures Association Arbitration Program:

(1) claims of a Customer, Client or Sponsored Person that is not a Participant against a Participant that relate to or arise

out of any Transaction on or subject to the SEF Rules, including any disputes brought under Rule 922(a); and

(2) [Reserved]

(3) at the discretion of the Chief Compliance Officer, any claim involving the interests of the SEF, its Participants, their

business relations or trading in general not otherwise arbitrable under these rules, provided the parties have

consented to such arbitration.

(d) Waiver of Any Objection to Jurisdiction.

Any Person who is not a Participant who submits a claim or grievance to arbitration or any Person who appeals any arbitration

decision, or who takes any steps therein, shall be conclusively presumed to have voluntarily recognized and agreed to the

jurisdiction of the NFA to hear and determine the claim or appeal.

RULE 1102 INITIATING AN ARBITRATION CLAIM

(a) A claimant may initiate a claim by submitting the required documents and fees to the NFA Arbitration Program. A claimant

shall provide notice of such arbitration claim to the SEF.

(b) An arbitration arising from or in connection with the SEF Rules must be brought to arbitration through by the NFA Arbitration

Program or another arbitration program permitted by the CFTC Regulations within two (2) years from the occurrence of the

event giving rise to the dispute.

(c) Each party to the dispute will bear its own costs and expenses in connection with any arbitration hereunder, as well as an

equal share of the administrative fees and the fees of the arbitrator; provided, however, that the arbitrator will be entitled to

include in any award a full reimbursement for the prevailing party’s costs and expenses, such party’s share of the

administrative fees and the fees of the arbitrator, or any combination of any or all of the above. In the event that this Rule

1102 is held to be unenforceable in connection with any dispute, (i) exclusive jurisdiction for any such dispute will reside in

any state or federal court sitting in the New York, NY metropolitan area, (ii) the SEF and the Participant involved in the dispute

will be presumed to have submitted to the personal jurisdiction of any such court, and (iii) an action to enforce any judgment

or decision of such court may be brought in the same court or in any other court with jurisdiction or venue.

Chapter 12 – Miscellaneous

RULE 1201 SEF PERSONNEL: TRADING AND MISUSE OF MATERIAL, NON-PUBLIC INFORMATION

(a) Except as provided by Rules 1201(b) and 1201(c), Officers and SEF employees are prohibited from:

(1) Trading, directly or indirectly, in any Commodity Interest traded on the SEF;
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(2) Trading, directly or indirectly, in any related Commodity Interest;

(3) Trading, directly or indirectly, in a Commodity Interest traded on other Swap Execution Facilities or any designated

contract markets, or cleared by a Derivatives Clearing Organizations if the Officer or employee has access to

material, non-public information concerning such Commodity Interest; and

(4) Trading, directly or indirectly, in a Commodity Interest traded on or cleared by a linked exchange if the employee has

access to material, non-public information concerning such commodity interest.

(b) The Chief Compliance Officer may exempt, in whole or in part, an Officer or SEF employee from the prohibitions of Rule

1201(a), if such Officer or SEF employee applies in writing for an exemption and demonstrates to the satisfaction of the Chief

Compliance Officer that the Officer or SEF employee meets all of the following criteria:

(1) the Officer or SEF employee does not have access to material, non-public information in the course of his or her

employment;

(2) the Officer or SEF employee agrees to provide the SEF with account statements and other documents relevant to

the Officer’s or SEF employee’s buying and selling of Contracts directly or indirectly; and

(3) the Officer or SEF employee agrees to inform the Chief Compliance Officer in writing of any material change that

may affect the Officer’s or SEF employee’s qualification for an exemption within one (1) Business Day of the change.

(c) With the Chief Compliance Officer’s written approval, Rule 1201(a) does not prohibit an Officer or SEF employee from

participating in a pooled investment vehicle or other investment vehicle whose investments are directed by a third-party

advisor if the Officer or SEF employee has no direct or indirect control over transactions executed by the investment vehicles.

(d) SEF Officials, employees, agents and independent contractors of the SEF are prohibited from disclosing material, non-public

information obtained as a result of his or her employment, agency relationship or engagement with the SEF where the SEF

Official, agent or independent contractor expected or should have reasonably expected that the information disclosed may

assist a Person in trading any Contract, any Contract traded on another exchange, or any related underlying commodity or

security.

(e) Rule 1201(d) shall not prohibit a SEF Official, agent or independent contractor of the SEF from disclosing material, non-public

information while discharging his or her official duties and responsibilities, including disclosures to another Self-Regulatory

Organization, linked exchange, court of competent jurisdiction, or a representative of any agency or department of the federal

or state government.

(f) For the purposes of this Rule 1201, the terms “material information,” “non-public information,” “linked exchange,” and “pooled

investment vehicle” each shall have the meaning set forth in CFTC Regulation § 1.59(a), or any successor regulation thereto.

RULE 1202 NO ENDORSEMENT OF OPINIONS, RESEARCH OR RECOMMENDATIONS

Any opinions, research or recommendations appearing on the Platform are not the SEF’s opinions, research or recommendations,

and the SEF does not endorse them or any content provided by third parties.

RULE 1203 NOT A PARTY

The SEF is not directly or indirectly a party to or participant in any trade or Swap executed on or pursuant to the rules of the SEF.

RULE 1204 NO ADVICE

The SEF is not providing and shall not provide any financial, legal, tax, advisory, consultative or business services to Participant,

or advice on structuring transactions or drafting or negotiating transaction documentation. Participant should seek its own legal,

tax, financial and other advice when structuring, negotiating and/or documenting transactions.

RULE 1205 GIFTS AND GRATUITIES

Except as permitted in writing by the Chief Executive Officer, no Participant shall, directly or indirectly, give or permit to be given

anything of value, including gifts and gratuities, in excess of one hundred dollars ($100) per individual per year to a SEF Official or

employee.
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RULE 1206 MARKET DATA AND INTELLECTUAL PROPERTY

(a) Subject to each Participant's rights in Participant’s own data as set forth in the Participant Documentation, the SEF shall have

a non-exclusive, royalty free, worldwide, perpetual license to any Participant’s Transaction Data, to use, distribute, or disclose

for the benefit of the SEF and shall own all rights, title and interest in and to all intellectual property and other proprietary

rights (including all copyright, patent, trademark or trade secret rights) in all derivative works based on Transaction Data to the

extent that such derived data is truly a derivative of the Transaction Data.

(b) Participant shall not, without the SEF’s prior written consent, directly or indirectly, sell, redistribute, or facilitate redistribution

of, all or any portion of the Transaction Data to any third party; provided, however, that such consent shall not be required for

(i) redistributing, or facilitating the redistribution of Transaction Data, (ii) copying, reproduction or re-transmission of

information that is generally available to the public free of charge, (iii) use of any part of the data on the Platform for

administrative, regulatory or reporting purposes of the Participant, (iv) the solicitation and entry of orders for trades on the

Platform, or (v) the provision of indicative valuations to Participant’s counterparties.

(c) Notwithstanding Rule 1206(b), any Transaction Data that Participant generates and provides to the SEF in connection with

Transactions shall be treated as the non-exclusive property of Participant and the SEF, each of whom shall have the right to

use, sell, retransmit and/or redistribute such Transaction Data; provided, however, that the SEF shall not use (or permit other

parties to use) Transaction Data to replicate or reverse engineer Participant’s trading strategies and shall not sell, retransmit

or redistribute Transaction Data unless such Transaction Data is anonymized, except in each case as required by Applicable

Law and/or any agreements that the SEF has entered into with Derivatives Clearing Organization(s).

(d) The SEF will not use for business or marketing purposes any Proprietary Data or Personal Information collected or received

from or on behalf of any Person for the purpose of fulfilling the SEF’s regulatory obligations.

(e) The SEF may share Proprietary Data or Personal Information with one or more Swap Execution Facilities, designated contract

markets, or the CFTC for regulatory purposes in accordance with Applicable Law.

(f) Each Participant, and other Persons affiliated with the Participant hereby acknowledges and agrees that the SEF may

disclose and disseminate Creation Data pursuant to these Rules.

(g) Each Participant, and other Persons affiliated with any of the foregoing hereby acknowledges and agrees that the SEF owns

and shall retain all right, title and interest in and to the SEF, all components thereof, including without limitation all related

applications, all application programming interfaces, user interface designs, software and source code and any and all

intellectual property rights therein, including, without limitation all registered or unregistered, as applicable copyright, trade

mark, service mark, trade secret, trade name, data or database rights, design rights, moral rights, inventions, whether or not

capable or protection by patent or registration, rights in commercial information or technical information, including know-how,

research and development data and manufacturing methods, patent, and other intellectual property and ownership rights,

including applications for the grant of any of the same, in or to the SEF and all other related proprietary rights of the SEF

and/or any of its affiliates (together, with any and all enhancements, corrections, bug fixes, updates and other modifications to

any of the foregoing and any and all data or information of any kind transmitted by means of any of the foregoing, “Proprietary

Information”). Each Participant, on behalf of itself and each of its affiliates and other Persons affiliated with any of the

foregoing, further acknowledges and agrees that the Proprietary Information is the exclusive, valuable and confidential

property of the SEF. Each Participant acknowledges and agrees that it shall not, and shall not permit its affiliates and other

Persons affiliated with any of the foregoing to, reverse engineer, copy, bug fix, correct, update, transfer, reproduce, republish,

broadcast, create derivative works based on or otherwise modify, in any manner, all or any part of the SEF or the Proprietary

Information. Each Participant further agrees to, and agrees to cause each of its affiliates and other Persons affiliated with any

of the foregoing to, keep the Proprietary Information confidential and not to transfer, rent, lease, loan, sell or distribute, directly

or indirectly, all or any portion of the SEF or any Proprietary Information.

RULE 1207 EXTENSION OR WAIVER OF RULES

If necessary and expedient, the SEF may, in its sole discretion, waive, or extend the time period for performing, any act or acts

designated by the SEF Rules, but only to the extent such waiver or extension is not inconsistent with the CEA or the CFTC

Regulations.

RULE 1208 EFFECT OF AMENDMENT, REPEAL OR NEW RULE

(a) These SEF Rules may be modified or amended by the SEF by posting such amendments to the SEF website, and any such
amendment shall be applicable to and binding and shall be effective when posted.

(b) If an amendment or repeal of a SEF Rule or adoption of a new SEF Rule does not materially change the terms or conditions

of a Contract and does not affect the value of open Contracts as determined by the Board in its sole discretion, then the

effective date of any amendment or repeal of a SEF Rule or adoption of a new SEF Rule relating to Contracts is binding on all

Contracts entered into before and after the effective date of such amendment, repeal or adoption.

(c) If an amendment or repeal of a SEF Rule or adoption of a new SEF Rule materially changes the terms or conditions of a

Contract or affects the value of open Contracts as determined by the Board in its sole discretion, then the amendment, repeal

or new SEF Rule is binding only on Contracts listed for trading after the effective date of such amendment, repeal or adoption,

and Contracts listed as of the effective date of such amendment, repeal or adoption with no open positions then in existence,

unless otherwise specifically provided by the Board.

RULE 1209 ANTITRUST CONSIDERATIONS

Neither the SEF nor its Directors, Officers or employees may take any action that results in an unreasonable restraint of trade or

imposes any anticompetitive burden on trading or clearing.

RULE 1210 GOVERNING LAW, JURISDICTION AND DISPUTE RESOLUTION

(a) The law of the State of New York governs the SEF Rules.

(b) Any dispute between the SEF and a Participant arising from or in connection with the SEF Rules will be settled by arbitration

pursuant to Chapter 11. All Participants unconditionally and irrevocably waive any and all right to trial by jury in connection

with any such dispute.

Chapter 13 – Contract Terms and Conditions

RULE 1301 NON-DELIVERABLE FORWARDS

NDF Contract Terms

Contract Overview A non-deliverable forward (NDF) is an outright forward contract in which counterparties

settle the difference between the contracted NDF price or rate and the prevailing spot

price or rate on an agreed notional amount, and where settlement is performed in

USD.

Reference Currency 1

&

Reference Currency 2

Non Deliverable Currencies

AFN Afghan Afghani

ALL Albanian Lek

ANG Netherlands Antillean Guilder

AOA Angolan Kwanza

ARS Argentine

Peso AWG Aruban

Florin

AZN Azerbaijanian Manat

BAM Bosnia-Herzegovina Convertible Mark

BMD Bermudan Dollar

BOB Bolivian Boliviano

BRL Brazilian Real

BYN Belarus Ruble

CDF Congolese Franc

CLP Chilean Peso

CNY Chinese Renminbi

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COP Colombian Peso

CVE Cape Verde Islands

Escudo DJF Djibouti Franc

EGP Egyptian Pound

ERN Eritrean Nakfa

GMD Gambia Dalasi

GTQ Guatemalan Quetzal

GYD Guyana Dollar

HTG Haitian Gourde

IDR Indonesian Rupiah

INR Indian Rupee

IQD Iraqi Dinar

KES Kenya

Shilling

KGS Kyrgyzstan Som

KHR Cambodian Riel

KMF Comoros Franc

KRW South Korean

Won

KYD Cayman Islands Dollar

KZT Kazakh Tenge

LAK Lao Kip

LRD Liberian Dollar

LSL Lesotho Loti

LYD Libyan Dinar

MMK Myanmar Kyat

MNT Mongolian Tugrik

MOP Macau Pataca

MRO Mauritania

Ouguiya MVR Maldives

Rufiyaa MYR Malaysian

Ringgit

MZN Mozambique Metical

NPR Nepali Rupee

PEN Peruvian Nuevo Sol

PHP Philippine Peso

PKR Pakistan Rupee

RUB Russian Ruble

SCR Seychelles Rupee

SLL Sierra Leone Leone

SRD Suriname Dollar

SSP South Sudan

Pound THB Thai Baht

TJS Tajikistani Somoni

TMT Turkmenistan New Manat

TWD Taiwan Dollar

UAH Ukrainian Hryvnia

UYU Uruguayan Peso

VEF Venezuelan Bolívar

VND Vietnamese Dong

VUV Vanuatu Vatu

XPF CPF Franc

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YER Yemeni Rial

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ZMW Zambian Kawacha

Deliverable Currencies

AED United Arab Emirates

Dirham AUD Australia Dollar

BGN Bulgaria Lev

BHD Bahraini Dinar

BWP Botswana Pula

CAD Canada Dollar

CHF Switzerland

Franc

CNH Offshore Chinese Renminbi

CZK Czech Republic Koruna

DKK Denmark Krone

EEK Estonia Kroon

EUR Euros

GBP United Kingdom Pound

HKD Hong Kong Dollar

HRK Croatia Kuna

HUF Hungary Forint

ILS Israel Shekel

ISK Iceland Krona

JMD Jamaica Dollar

JOD Jordan Dinar

JPY Japan Yen

KWD Kuwait Dinar

LKR Sri Lanka Rupee

LVL Latvia Lats

MAS Morocco Dirham

MUR Mauritius Rupee

MXN Mexico Peso

NOK Norway Krone

NZD New Zealand Dollar

OMR Oman Rial

PLN Poland Zloty

QAR Qatar Riyal

RON Romania New Leu

RSD Serbia Dollar

SAR Saudi Arabia

Riyal SEK Sweden

Krona SGD Singapore

Dollar SKK Slovakia

Koruna TND Tunisia

Dollar TOP Tonga

Pa’anga TRY Turkey

Lira

USD U.S. Dollar

WST Western Samoan Tala

XOF West African CFA

Franc ZAR South Africa

Rand

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ZWD Zimbabwe Dollar

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Settlement Currency Non-deliverable forwards (NDFs) settle in USD

Quoting Convention

and Minimum Increment

Notional amount, as agreed by the counterparties

Minimum Size Notional amount, as agreed by the counterparties

Notional Currency Currency in which the contract size is expressed in

Trading Conventions Buy or Sell which refers to the contract size expressed in notional currency

Forward Rate Currency exchange rate expressed as the amount of reference currency per unit of

non- reference currency

Trade Date The date on which parties enter into the contract

Settlement Date Specified settlement or payment date

Fixing Date The date at which the forward rate is calculated

Settlement Procedure Bilateral settlement performed in the Settlement Currency

Trading Hours 13:00 Sunday - 17:00 Friday Eastern Time

Clearing Venue Bilateral

Block Size As set forth in Appendix F to Part 43 of the CFTC Regulations

Speculative Limits As set forth in CFTC 17 CFR Part 150

Reportable Levels As set forth in CFTC Regulation 15.03

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Spot FX Rate Calculation

For NDFs consisting of a Deliverable and Non-Deliverable Currency as Reference Currencies, the Spot FX Rate will be derived

from a combination of (1) the spot rate identified in the relevant EMTA, Inc. (“EMTA”) Template for the applicable Non-Deliverable

Currency assuming USD as the Settlement Currency (the “Non-Deliverable Spot Rate”), and (2) the WM/Reuters 4:00 pm Closing

Spot Rate for the applicable Deliverable Currency against USD; provided, however, that if the WM/Reuters Closing Spot Rate is

quoted in units to a non-USD currency, then the Closing Spot Rate shall be converted to USD in accordance with Section 6 of the

WM/Reuters Spot & Forward Rates Methodology Guide, as amended and supplemented from time to time, or any successor

thereto. The Non-Deliverable Spot Rate shall incorporate all of the EMTA template terms then in effect as recommended by EMTA

or a recognized successor that are applicable to the Non-Deliverable Currency (assuming USD as the Settlement Currency).
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For NDFs consisting of two Non-Deliverable Currencies as Reference Currencies, the Spot FX Rate will be derived from a

combination of the Non-Deliverable Spot Rate for each of the applicable Non-Deliverable Currencies, assuming USD as the

Settlement Currency. The Non-Deliverable Spot Rates shall incorporate all of the EMTA template terms then in effect as

recommended by EMTA or a recognized successor that are applicable to the Non-Deliverable Component Pair (assuming USD

as the Settlement Currency).

For NDFs consisting of two Deliverable Currencies as Reference Currencies, the Spot FX Rate will be derived from a combination

of the WM/Reuters 4:00 pm Closing Spot Rate for both of the applicable Deliverable Currencies against USD; provided, however,

that if the WM/Reuters Closing Spot Rate for one or both Deliverable Currencies is quoted in units to a non-USD currency, then the

Closing Spot Rate for such currency or currencies shall be converted to USD in accordance with Section 6 of the WM/Reuters Spot

& Forward Rates Methodology Guide, as amended and supplemented from time to time, or any successor thereto.
RULE 1302 CROSS-CURRENCY NDF

Cross-Currency NDF Contract Terms

Contract Overview A cross-currency non-deliverable forward (“NDF”) is an outright

forward contract in which counterparties settle the difference between

the contracted NDF price or rate and the prevailing spot price or rate on

an agreed notional amount, and where settlement may be performed in

certain currencies other than USD.

Reference Currency 1

&

Reference Currency 2

Non Deliverable Currencies

ARS Argentine Peso

BRL Brazilian Real

CLP Chilean Peso

CNY Chinese Renminbi

COP Colombian Peso

EGP Egyptian Pound

GTQ Guatemalan

Quetzal IDR Indonesian

Rupiah INR Indian Rupee

KES Kenya Shilling

KRW South Korean

Won KZT Kazakh Tenge

MYR Malaysian Ringgit

PEN Peruvian Nuevo Sol

PHP Philippine Peso

PKR Pakistan Rupee

RUB Russian Ruble

THB Thai Baht

TWD Taiwan Dollar

UAH Ukrainian Hryvnia

UYU Uruguayan Peso

VEF Venezuelan Bolívar

VND Vietnamese Dong

Deliverable Currencies

AED United Arab

Emirates Dirham

AUD Australia Dollar

BGN Bulgaria Lev

BWP Botswana Pula

CAD Canada Dollar

CHF Switzerland Franc

CNH Offshore Chinese Renminbi

CZK Czech Republic Koruna

DKK Denmark Krone

EEK Estonia Kroon

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EUR Euros

GBP United Kingdom Pound

HKD Hong Kong Dollar

HRK Croatia Kuna

HUF Hungary Forint

ILS Israel Shekel

ISK Iceland Krona

JMD Jamaica Dollar

JOD Jordan Dinar

JPY Japan Yen

KWD Kuwait Dinar

LKR Sri Lanka Rupee

LVL Latvia Lats

MAS Morocco Dirham

MUR Mauritius Rupee

MXN Mexico Peso

NOK Norway Krone

NZD New Zealand Dollar

OMR Oman Rial

PLN Poland Zloty

QAR Qatar Riyal

RON Romania New Leu

RSD Serbia Dollar

SAR Saudi Arabia

Riyal SEK Sweden

Krona SGD Singapore

Dollar SKK Slovakia

Koruna TND Tunisia

Dollar TRY Turkey Lira

USD U.S. Dollar

XOF West African CFA

Franc ZAR South Africa

Rand

ZWD Zimbabwe Dollar\

Settlement Currency AUD Australia Dollar

CAD Canada Dollar

CHF Switzerland Franc

DKK Denmark Krone

EUR Euros

GBP United Kingdom Pound

HKD Hong Kong Dollar

JPY Japan Yen

MXN Mexico Peso

NOK Norway Krone

NZD New Zealand Dollar

PLN Poland Zloty

SEK Sweden Krona

SGD Singapore Dollar

ZAR South Africa Rand

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BRL Brazilian Real

CNY Chinese

Renminbi INR Indian

Rupee

KES Kenya Shilling

KZT Kazakh Tenge

PKR Pakistan Rupee

Quoting Convention

and Minimum Increment

Notional amount, as agreed by the counterparties

Minimum Size Notional amount, as agreed by the counterparties

Notional Currency Currency in which the contract size is expressed in

Trading Conventions Buy or Sell which refers to the contract size expressed in Notional Currency

Forward Rate Currency exchange rate expressed as the amount of Reference Currency 1 per unit

of Reference Currency 2 per unit of Settlement.

Trade Date The date on which parties enter into the contract

Settlement Date Specified settlement or payment date

Fixing Date The date at which the forward rate is calculated

Settlement Procedure Bilateral settlement performed in the Settlement Currency

Trading Hours 13:00 Sunday - 17:00 Friday Eastern Time

Clearing Venue Bilateral

Block Size As set forth in Appendix F to Part 43 of the CFTC Regulations

Speculative Limits As set forth in CFTC 17 CFR Part 150

Reportable Levels As set forth in CFTC Regulation 15.03

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Spot FX Rate Calculation

For Cross-Currency NDFs consisting of a Deliverable and Non-Deliverable Currency as Reference Currencies, a base exchange

rate, expressed in USD (the “Base Exchange Rate”) will be derived from a combination of (1) the spot rate identified in the relevant

EMTA, Inc. (“EMTA”) Template for the applicable Non-Deliverable Currency assuming USD as the Settlement Currency (the “NonDeliverable Spot Rate”), and (2) the WM/Reuters 4:00 pm Closing Spot Rate for the applicable Deliverable Currency against USD;

provided, however, that if the WM/Reuters Closing Spot Rate is quoted in units to a non-USD currency, then the Closing Spot Rate

shall be converted to USD in accordance with Section 6 of the WM/Reuters Spot & Forward Rates Methodology Guide, as

amended and supplemented from time to time, or any successor thereto. The Non-Deliverable Spot Rate shall incorporate all of the

EMTA template terms then in effect as recommended by EMTA or a recognized successor that are applicable to the

Non-Deliverable Currency (assuming USD as the Settlement Currency). The Spot FX Rate will then be derived from the

WM/Reuters 4:00 pm Closing Spot Rate for the Settlement Currency against the Base Exchange Rate; provided, however, that if

the WM/Reuters Closing
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Spot Rate is quoted in units to a non-USD currency, then the Closing Spot Rate shall be converted to USD in accordance with

Section 6 of the WM/Reuters Spot & Forward Rates Methodology Guide, as amended and supplemented from time to time, or

any successor thereto.

For Cross-Currency NDFs consisting of two Non-Deliverable Currencies as Reference Currencies, the Base Exchange Rate will be

derived from a combination of the Non-Deliverable Spot Rate for each of the applicable Non-Deliverable Currencies, assuming

USD as the Settlement Currency. The Base Exchange Rate shall incorporate all of the EMTA template terms then in effect as

recommended by EMTA or a recognized successor that are applicable to the Non-Deliverable Component Pair (assuming USD as

the Settlement Currency). The Spot FX Rate will then be derived from the WM/Reuters 4:00 pm Closing Spot Rate for the

Settlement Currency against the Base Exchange Rate; provided, however, that if the WM/Reuters Closing Spot Rate is quoted in

units to a non-USD currency, then the Closing Spot Rate shall be converted to USD in accordance with Section 6 of the

WM/Reuters Spot & Forward Rates Methodology Guide, as amended and supplemented from time to time, or any successor

thereto.

For Cross-Currency NDFs consisting of two Deliverable Currencies as Reference Currencies, the Base Exchange Rate will be

derived from a combination of the WM/Reuters 4:00 pm Closing Spot Rate for both of the applicable Deliverable Currencies against

USD; provided, however, that if the WM/Reuters Closing Spot Rate for one or both Deliverable Currencies is quoted in units to a

non-USD currency, then the Closing Spot Rate for such currency or currencies shall be converted to USD in accordance with

Section 6 of the WM/Reuters Spot & Forward Rates Methodology Guide, as amended and supplemented from time to time, or any

successor thereto. The Spot FX Rate will then be derived from the WM/Reuters 4:00 pm Closing Spot Rate for the Settlement

Currency against the Base Exchange Rate; provided, however, that if the WM/Reuters Closing Spot Rate is quoted in units to a

non- USD currency, then the Closing Spot Rate shall be converted to USD in accordance with Section 6 of the WM/Reuters Spot &

Forward Rates Methodology Guide, as amended and supplemented from time to time, or any successor thereto.
RULE 1303 FX OPTIONS

FX Option Contract Terms

Contract Overview A Foreign Exchange Option (FX option) is a derivative financial instrument that

gives the buyer the right, but not the obligation, to buy or sell a specific quantity of

one foreign currency in exchange for another currency at a pre-arranged fixed price

on a specific date.

Trade Date The date on which the parties enter into the contract

Option Style European – a European option may only be exercised at the expiration date of

the option.

Option Type Call option – the right to purchase a currency pair at a given exchange rate in

the future.

Put option – the right to sell a currency pair at a given exchange rate in the future.

Call Currency Currency for a call option

Put currency Currency for a put option

Expiration Date Date at which the option contract expires

Expiration Time Time at which the option contract expires

Settlement Date Settlement date of the option contract

Premium Amount expressed in premium currency

Premium Date Date on which the premium is due

Quoting Convention

and Minimum Increment

Notional amount, as agreed by the counterparties

Minimum Size Notional amount, as agreed by the counterparties

Notional Currency Currency in which the contract size is expressed in

Settlement Procedure Bilateral settlement performed in the settlement currency

Trading Hours 13:00 Sunday - 17:00 Friday Eastern Time

Clearing Venue Bilateral

Block Size As set forth in Appendix F to Part 43 of the CFTC Regulations

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Speculative Limits As set forth in CFTC 17 CFR Part 151

Reportable Levels As set forth in CFTC Regulation 15.03

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Annex A – Appropriate Minimum Block Sizes

Annex A – Appropriate Minimum Block Sizes

The appropriate minimum block sizes for foreign exchange swaps set forth by the CFTC in Appendix F to Part 43 of the

CFTC Regulations, as of November 16, 2015, are reproduced below.

Super-major currencies

EUR

(Euro)

GBP

(British pound)

JPY

(Japanese yen)

USD

(U.S. dollar)

Super-major currencies EUR 6,250,000 6,250,000 18,750,000

GBP *6,250,000 6,250,000 6,250,000

JPY *6,250,000 *6,250,000 1,875,000,000

USD *18,750,000 *6,250,000 *1,875,000,000

Major currencies AUD *6,250,000 0 10,000,000 10,000,000

CAD *6,250,000 0 10,000,000 10,000,000

CHF *6,250,000 *6,250,000 12,500,000 12,500,000

DKK 0 0 0 0

KRW 0 0 0 6,250,000,000

SEK *6,250,000 0 0 100,000,000

NOK *6,250,000 0 0 100,000,000

NZD 0 0 0 5,000,000

ZAR 0 0 0 25,000,000

Non-major currencies BRL 0 0 0 5,000,000

CZK 200,000,000 0 0 200,000,000

HUF 1,500,000,000 0 0 1,500,000,000

ILS 0 0 0 50,000,000

MXN 0 0 0 50,000,000

PLN 25,000,000 0 0 25,000,000

RMB 50,000,000 0 50,000,000 50,000,000

RUB 0 0 0 125,000,000

TRY *6,250,000 0 0 *10,000,000

All values that do not have an asterisk are denominated in the currency of the left hand side.

All values that have an asterisk (*) are denominated in the currency indicated on the top of the table.
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Refinitiv US SEF Rulebook

Effective December 8, 

2020March 2, 2021
Refinitiv US SEF Rulebook

Effective December 8, 

2020March 2, 2021
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Description #12473511v7<AmericasActive> - Refinitiv SEF Rulebook

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