Information Classification: General 

A-1 

Exhibit A 

Explanation of Amendments to SwapEx Rulebook 

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

Rulebook. 

Amendment Explanation 

Rule 302 

Amended to (1) add a new subsection (a)(3) to require any 

Participant who accesses, or whose Authorized Users access, the 

Trading System from Singapore to represent that such Participant 

is an accredited investor, an expert investor or an institutional 

investor as those terms are defined in the Securities and Futures 

Act of Singapore and (2) renumber subsequent subsections of the 

rule 

Rule added to align with the 

requirements under 

regulations issued by the 

Monetary Authority of 

Singapore (“MAS”) 

exempting certain 

derivatives trading venues 

regulated by the CFTC from 

the requirement to be a 

MAS-authorized approved 

exchange or recognized 

market operator 

Rule 304 

Amended to (1) add a new subsection (c)(4) to require any 

Authorized Trade who accesses, or whose Authorized Users 

access, the Trading System from Singapore to represent that such 

Authorized Trader is an accredited investor, an expert investor or 

an institutional investor as those terms are defined in the 

Securities and Futures Act of Singapore and (2) renumber 

subsequent subsections of the rule 

Rule added to align with the 

requirements under 

regulations issued by the 

Monetary Authority of 

Singapore (“MAS”) 

exempting certain 

derivatives trading venues 

regulated by the CFTC from 

the requirement to be a 

MAS-authorized approved 

exchange or recognized 

market operator 
Information Classification: General 

B-1 

Exhibit B 

Rulebook (clean) 

Rule 302. Participant Eligibility Requirements 

(a) To be eligible for admission as a Participant, an applicant must be able to demonstrate to 

the satisfaction of the Company that it: 

(1) is an Eligible Contract Participant, and, if applicable, is in compliance with 

CFTC Regulation 1.17; 

(2) is located in, and will access and use the Trading System and permit its 

Authorized Users to access and use the Trading System solely from, the United States or 

a jurisdiction in which the Company is permitted by Applicable Law to offer the Trading 

System and, if the applicant or any of its Authorized Traders is organized or established 

under the laws of a country other than the United States or intends to access and use the 

Trading System or permits their respective Authorized Users to access and use the 

Trading System from a jurisdiction other than the United States, the applicant shall 

submit, upon request by the Company, an opinion of appropriately qualified and 

reputable outside counsel on home country law and, if applicable, other relevant nondomestic law, in form and substance acceptable to the Company; 

(3) is, if such Participant or its Authorized User accesses the Trading System 

from Singapore, an accredited investor, an expert investor or an institutional investor as 

these terms are defined in the Securities and Futures Act of Singapore; 

(4) has all registrations, licenses and consents required by its constituent 

documents and by Applicable Law to trade Contracts on the Trading System and is not 

subject to any trading ban, prohibition or suspension issued by the CFTC or by any SelfRegulatory Organization that is subject to the CFTC’s oversight, including the NFA; 

(5) with respect to Contracts that are to be cleared by a Derivatives Clearing 

Organization, (i) is a member of a Derivatives Clearing Organization that is authorized 

to clear Contracts for its own account and, if applicable, for the account(s) of its 

Customers, Authorized Traders and its and their Customers or (ii) has delivered to the 

Company evidence satisfactory to the Company, in its sole discretion, that at least one 

Clearing Firm has agreed to accept Contracts for clearing into the account of such 

Participant and/or, if applicable, its Authorized Traders and its and/or their Customers; 

and 

(6) is of good reputation and business integrity, maintains adequate financial 

resources and credit, and satisfies such other criteria as the Company may establish from 

time to time. 
Information Classification: General 

B-2 

(b) Once admitted, a Participant shall continue to comply with all applicable eligibility criteria 

in Rule 302(a) and shall provide the Company with such information in relation thereto as the Company 

may require. 

(c) Each Participant shall immediately notify the Company in writing if it ceases to meet any 

of the requirements of Rule 302(a). 

... 

Rule 304. Participant Eligibility Requirements 

(a) A Participant may grant permission to one or more Authorized Traders to enter Orders and 

Indications of Interest, originate and respond to Requests for Quotes, and otherwise access the Trading 

System in accordance with the criteria and procedures established by the Company. 

(b) By agreeing to act as an Authorized Trader, such Person agrees to be bound by the duties 

and responsibilities of an Authorized Trader under the Rules and other Company Requirements and to be 

subject to, and comply with, the Rules. 

(c) An Authorized Trader must at all times: 

(1) be an Eligible Contract Participant; 

(2) if applicable, be in compliance with CFTC Regulation 1.17; 

(3) be located in and access and use the Trading System, and permit its 

Authorized Users to access and use the Trading System, solely from within the United 

States or a jurisdiction in which the Company is permitted by Applicable Law to offer 

the Trading System; 

(4) be, to the extent such Authorized Trader or its Authorized Users accesses 

the Trading System from Singapore, an accredited investor, an expert investor or an 

institutional investor as these terms are defined in the Securities and Futures Act of 

Singapore; 

(5) ensure that activity conducted under the User IDs assigned to it and its 

Authorized Users complies with the Rules; 

(6) have the authority, at the Company’s request, to adjust or withdraw any 

Order or Request for Quote submitted under such User IDs; 

(7) have and maintain all necessary regulatory approvals and/or licenses to 

operate as an Authorized Trader and not be subject to any trading ban, prohibition or 

suspension issued by the CFTC or by any Self-Regulatory Organization that is subject to 

CFTC oversight, including the NFA; and 

(8) agree to such other terms and conditions as may be established by the 

Company from time to time. 
Information Classification: General 

B-3 

(d) The Company will promptly notify a Participant in writing of its approval, or refusal to 

approve, the designation of an Authorized Trader. The Company may, in its sole discretion, revoke or 

suspend the designation of an Authorized Trader, and shall promptly notify the Participant in writing of 

such action in accordance with procedures established by the Company. 

(e) Each Authorized Trader shall immediately notify the Company in writing if it ceases to 

meet any of the requirements of Rule 304(c). Participant shall notify the Company in writing if it becomes 

aware that any of its Authorized Traders ceases to meet any of the requirements of Rule 304(c). 

(f) A Participant that seeks to terminate the designation of an Authorized Trader shall notify 

the Company in writing, providing such information as the Company may require. The Company shall 

terminate the Trading Privileges of such Authorized Trader and its Authorized Users in accordance with 

procedures established by the Company.
Information Classification: General 

C-1 

Exhibit C 

Rulebook (redline) 

Rule 302. Participant Eligibility Requirements 

(a) To be eligible for admission as a Participant, an applicant must be able to demonstrate to 

the satisfaction of the Company that it: 

(1) is an Eligible Contract Participant, and, if applicable, is in compliance with 

CFTC Regulation 1.17; 

(2) is located in, and will access and use the Trading System and permit its 

Authorized Users to access and use the Trading System solely from, the United States or 

a jurisdiction in which the Company is permitted by Applicable Law to offer the Trading 

System and, if the applicant or any of its Authorized Traders is organized or established 

under the laws of a country other than the United States or intends to access and use the 

Trading System or permits their respective Authorized Users to access and use the 

Trading System from a jurisdiction other than the United States, the applicant shall 

submit, upon request by the Company, an opinion of appropriately qualified and 

reputable outside counsel on home country law and, if applicable, other relevant nondomestic law, in form and substance acceptable to the Company; 

(2)(3) is, if such Participant or its Authorized User accesses the Trading 

System from Singapore, an accredited investor, an expert investor or an institutional 

investor as these terms are defined in the Securities and Futures Act of Singapore;

(3)(4) has all registrations, licenses and consents required by its constituent 

documents and by Applicable Law to trade Contracts on the Trading System and is not 

subject to any trading ban, prohibition or suspension issued by the CFTC or by any SelfRegulatory Organization that is subject to the CFTC’s oversight, including the NFA; 

(4)(5) with respect to Contracts that are to be cleared by a Derivatives 

Clearing Organization, (i) is a member of a Derivatives Clearing Organization that is 

authorized to clear Contracts for its own account and, if applicable, for the account(s) of 

its Customers, Authorized Traders and its and their Customers or (ii) has delivered to the 

Company evidence satisfactory to the Company, in its sole discretion, that at least one 

Clearing Firm has agreed to accept Contracts for clearing into the account of such 

Participant and/or, if applicable, its Authorized Traders and its and/or their Customers; 

and 

(5)(6) is of good reputation and business integrity, maintains adequate 

financial resources and credit, and satisfies such other criteria as the Company may 

establish from time to time. 
Information Classification: General 

C-2 

(b) Once admitted, a Participant shall continue to comply with all applicable eligibility criteria 

in Rule 302(a) and shall provide the Company with such information in relation thereto as the Company 

may require. 

(c) Each Participant shall immediately notify the Company in writing if it ceases to meet any 

of the requirements of Rule 302(a). 

... 

Rule 304. Participant Eligibility Requirements 

(a) A Participant may grant permission to one or more Authorized Traders to enter Orders and 

Indications of Interest, originate and respond to Requests for Quotes, and otherwise access the Trading 

System in accordance with the criteria and procedures established by the Company. 

(b) By agreeing to act as an Authorized Trader, such Person agrees to be bound by the duties 

and responsibilities of an Authorized Trader under the Rules and other Company Requirements and to be 

subject to, and comply with, the Rules. 

(c) An Authorized Trader must at all times: 

(1) be an Eligible Contract Participant; 

(2) if applicable, be in compliance with CFTC Regulation 1.17; 

(3) be located in and access and use the Trading System, and permit its 

Authorized Users to access and use the Trading System, solely from within the United 

States or a jurisdiction in which the Company is permitted by Applicable Law to offer 

the Trading System; 

(4) be, to the extent such Authorized Trader or its Authorized Users accesses 

the Trading System from Singapore, an accredited investor, an expert investor or an 

institutional investor as these terms are defined in the Securities and Futures Act of 

Singapore; 

(4)(5) ensure that activity conducted under the User IDs assigned to it and 

its Authorized Users complies with the Rules; 

(5)(6) have the authority, at the Company’s request, to adjust or withdraw 

any Order or Request for Quote submitted under such User IDs; 

(6)(7) have and maintain all necessary regulatory approvals and/or licenses 

to operate as an Authorized Trader and not be subject to any trading ban, prohibition or 

suspension issued by the CFTC or by any Self-Regulatory Organization that is subject to 

CFTC oversight, including the NFA; and 

(7)(8) agree to such other terms and conditions as may be established by 

the Company from time to time. 
Information Classification: General 

C-3 

(d) The Company will promptly notify a Participant in writing of its approval, or refusal to 

approve, the designation of an Authorized Trader. The Company may, in its sole discretion, revoke or 

suspend the designation of an Authorized Trader, and shall promptly notify the Participant in writing of 

such action in accordance with procedures established by the Company. 

(e) Each Authorized Trader shall immediately notify the Company in writing if it ceases to 

meet any of the requirements of Rule 304(c). Participant shall notify the Company in writing if it becomes 

aware that any of its Authorized Traders ceases to meet any of the requirements of Rule 304(c). 

(f) A Participant that seeks to terminate the designation of an Authorized Trader shall notify 

the Company in writing, providing such information as the Company may require. The Company shall 

terminate the Trading Privileges of such Authorized Trader and its Authorized Users in accordance with 

procedures established by the Company.