Bloomberg SEF LLC 731 Lexington Avenue Tel +1 212 318 2000

New York, NY 10022 bloombergsef.com

September 15, 2022 

Submitted via Portal

Melissa Jurgens

Office of the Secretariat

U.S. Commodity Futures Trading Commission 

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581 

Re: Bloomberg SEF LLC – Certification 2022-R-1 (Notice to Participants)

Dear Sir or Madam:

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

regulations of the U.S. Commodity Futures Trading Commission (the “Commission”), 

Bloomberg SEF LLC (“BSEF”) hereby notifies the Commission that BSEF released the Notice 

to Participants attached hereto as Exhibit A on September 15, 2022 (the “Notice”). 

The Notice informed Participant about matters related to errors and omissions in previously 

reported data including a specific type of error identified in CFTC Staff Letter 22-06 regarding 

swaps that remain erroneously open at swap data repositories. 

BSEF hereby certifies that: (i) the Notice to Participants complies with the Act and the 

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

on SEF’s website. There were no substantive opposing views to the Notice to Participants. 

The Notice is effective September 16, 2022. 
U.S. Commodity Futures Trading Commission 

Page 2

Please contact the undersigned at (212) 617-7331 with any questions regarding this matter. 

Thank you for your attention to this matter.

an Glatter

Chief Compliance Officer

Bloomberg SEF LLC 

73I Lexington Avenue 

New York, NY I0022

cc: Marilee Dahlman, Division of Market Oversight, U.S. Commodity Futures 

Trading Commission
EXHIBIT A 
Bloomberg SEF LLC

Notice to Participants No. 2022-1 

Termination of Certain Swap Transactions Executed on the SEF operated by BSEF.

Capitalized terms used, but not defined herein, shall have the meanings ascribed to them in the

BSEF Rulebook. 

BSEF recommends that all of its Participants review CFTC Staff Advisory on Reporting of Errors 

and Omissions in Previously Reported Data dated June 10, 2022.

Some Participants are acting on the SEF operated by BSEF as agents for several clients

(“Agents”) and facilitate a single swap transaction on behalf of such several accounts (“Initial 

Swap”). Such Participants allocate a portion of the executed swap to each client. 

BSEF will execute the Initial Swap and report it to the SDR indicated in the BSEF Rulebook with 

allocation indicator PREA. Please refer to CFTC Rules 45.3(c) and 45.5 (e) with respect to 

subsequent reporting obligations of Agents and counterparties to the Initial Trade. 

It is an obligation of the reporting counterparty (determined as set forth in BSEF Rule 523) to an 

Initial Swap to report all continuation data with respect to such Initial Swap to the SDR, including 

the termination of the Initial Swap. The reporting counterparty must terminate the Initial Swap 

upon submission of each swap resulting from allocation to an SDR. See CFTC Rules 45.3(c)(2) 

and 54.5(e)(2).

Please note that with respect to swaps intended to be cleared, an Initial Swap is not an original 

swap as defined in CFTC Rule 45.1. It is an obligation of the applicable clearing house to 

terminate an original swap in the SDR.

To terminate an Initial Swap in BSEF’s SDR, DTCC Data Repository LLC (DDR), a reporting 

counterparty will need the following information:

• USI/UTI of the Initial Swap as provided on the BSEF Trade confirmation

• LEI of the Reporting Counterparty

• LEI of non-Reporting Counterparty or, if not available, BSEF’s LEI

5493003IUYOH354SNS58

Please note that BSEF will report a swap “allocated” to only one account with UNAL 

indicator and the LEI of the counterparty. A reporting counterparty is not required to 

comply with CFTC Rule 45.3(c) and 45.5(e) with respect to such UNAL swaps.

Capitalized terms used, but not defined herein, shall have the meanings ascribed to them in the 

Bloomberg SEF Rulebook.

Effective Date: September 16, 2022