17 State Street › New York, NY 10004 › cboe.com

December 15, 2022

Submitted via CFTC Portal

Office of the Secretariat 

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street

Washington, DC 20581

Re: Submission of Cboe SEF, LLC Rule Amendments (Submission No. 22-15) 

Dear All:

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

regulations of the Commodity Futures Trading Commission (Commission), Cboe SEF, LLC (Cboe

SEF) hereby notifies the Commission that it is publishing a revised fee schedule (the “Fee 

Schedule”) as a Fee-related Rule, adding options for Participants to access its New York matching 

engine located in the Equinix NY5 data center from (1) a London wide area network located in 

the Equinix LD4 data center (Transatlantic Connectivity) or (2) a Tokyo point of presence (PoP) 

located in the Equinix TY3 data center (Transpacific Connectivity).

Cboe SEF is also adding categories for ISV Fees and Messaging Fees. In accordance with Rules 

321 and 324, Participants may access the SEF Trading System via a SEF ISV. To the extent a SEF 

ISV charges fees (ISV Fees) as a result of a Participant’s activity on the SEF, Cboe SEF is clarifying 

that such fees will be passed through to the relevant Participant. Cboe SEF is making a similar 

addition regarding fees charged by third-party vendors providing post-trade messaging services 

(Messaging Fees). Specifically, to the extent such a third-party charges Messaging Fees, such 

fees will be passed through to the relevant Participant. 

A marked copy of the Fee Schedule is attached hereto as Exhibit A, and a clean copy, as amended, 

attached hereto as Exhibit B. The revised Fee Schedule will be effective on January 1, 2023.

Cboe SEF certifies that the Fee Schedule complies with the CEA and the Commission’s regulations. 

Cboe SEF has reviewed the swap execution facility core principles (Core Principles) as set forth 

in the CEA and has determined that the Fee Schedule complies with the requirements of impartial 

access in Core Principle 2 and Commission Regulation 37.202 because all fees and any discounts 

will be applied on an impartial, fair, and non-discriminatory manner and the Fee Schedule will be 

made transparent to all Participants. 
U.S. Commodity Futures Trading Commission

December 15, 2022

Page 2

17 State Street › New York, NY 10004 › cboe.com

In addition, in compliance with Core Principle 2 and Commission Regulation 37.200, the Fee 

Schedule does not incentivize manipulative trading or market abuse or impact Cboe SEF’s ability 

to perform its trade practice and market surveillance obligations under the CEA, and Cboe SEF’s 

Regulatory Division will continue to monitor trading to seek to prevent manipulative trading and 

market abuse. The Fee Schedule also complies with the requirements for monitoring and trade 

processing in Core Principle 4 and Commission Regulation 37.401, and the recordkeeping and 

reporting requirements in Core Principle 10 and Commission Regulations 37.1000 and 37.1001. 

Cboe SEF further certifies that this submission has been concurrently posted on its website at 

http://markets.cboe.com/global/fx/sef/resources. No substantive opposing views were 

expressed with respect to this Fee-related Rule.

If you have any questions regarding this submission, please contact me at (312) 786-7153 or 

mmargolis@cboe.com. 

Sincerely, 

/s/ Michael H. Margolis 

Michael H. Margolis

Assistant General Counsel

Cboe SEF, LLC

Attachments 
Submission Date – December 15, 2022

Page A‐1

EXHIBIT A

DUES, FEES, AND OTHER CHARGES

A. List of all dues, fees, or other charges

The only services for which Cboe SEF, LLC (“Cboe SEF”) will charge its Participants are trade

execution services and, for some Participants, connectivity fees to access the SEF Trading System, as

follows:

1. Transaction Fees:  Transaction Fees will be charged on the basis of each Transaction, and

may vary depending on the tenor and currency pair of each Contract.  Different pricing may

be charged depending on whether the Participant has acted in a “passive” or “removing”

capacity in connection with each such Transaction.  In connection with each Transaction,

Cboe SEF systematically identifies each Participant counterparty as either passive or

aggressive (removing) and charges fees in respect of each such category of Participant

counterparty.  Specifically, Cboe SEF identifies as “passive” the Participant counterparty

whose Order resided on the order book and subsequently matched against an inbound

Order, while Cboe SEF identifies as “aggressive” or “removing” the Participant counterparty

submitting such inbound Order.

2. Connectivity Fees:  Participants may be charged connectivity fees to access the SEF Trading

System.  Cboe SEF will charge Connectivity Fees for each physical connection a Participant

establishes with the SEF Trading System.  Cboe SEF will not charge for connectivity via either

its Transatlantic or Transpacific point of presence.  Cboe SEF will pass through all data center

cross‐connect charges, if applicable.  Cboe SEF may also charge fees on a per‐session basis.

3. ISV Fees:  In accordance with Rules 321 and 324, Participants may access the SEF Trading

System via a SEF ISV.  ISV Fees incurred by Cboe SEF as a result of a Participant’s activity

on the SEF will be passed through to that Participant, as applicable.  

2.4. Messaging Fees:  Participants may use third‐party vendors for post‐trade messaging

services.  Messaging Fees incurred by Cboe SEF as a result of a Participant’s activity on the

SEF will be passed through to that Participant, as applicable.

B. Description of the basis for all dues, fees, or other charges

There are two categories of Participants that can execute Transactions on Cboe SEF:  A Trading Firm

may execute Transactions on behalf of and as agent of a Prime Broker; and a Principal Trading Firm

may execute Transactions on its own behalf.  Cboe SEF charges Participants that are Trading Firms or

Principal Trading Firms a Fee for each Transaction executed on the SEF Trading System.  The Fee is

based on the Notional Amount in USD of each Transaction and is charged as a dollar amount per

USD million of Notional Amount.  A minimum Transaction Fee of USD 1.00 per Transaction is also

charged in respect of any Order submitted to the SEF Trading System.
    Submission Date – December 15, 2022

Page A‐2

Transaction Fees

Currency Pair Tenor Passive Fee  

(in USD, per USD 1mm of

Notional Amount)

Removing (Aggressing) Fee

(in USD, per USD 1mm of

Notional Amount)

All All 5.00 10.00
    Submission Date – December 15, 2022

Page A‐3

Connectivity Fees

Physical Connectivity

Pricing:

     

Bandwidth Installation Monthly Fee

1G and Below no charge $500.00 / connection

10G no charge $1,000.00 / connection

Transatlantic

Connectivity (LD4 to

NY5)

no charge Free

Transpacific

Connectivity (TY3 to

NY5)

no charge Free

Session Charges:    Monthly Fee

FIX Order Entry    Free

FIX BookFeed  

(Market Data)

   Free

ITCH   Free

ISV Fees – Pass Through

Messaging Fees – Pass Through
Submission Date – December 15, 2022 

Page B-1 

EXHIBIT B 

DUES, FEES, AND OTHER CHARGES

A. List of all dues, fees, or other charges

The only services for which Cboe SEF, LLC (“Cboe SEF”) will charge its Participants are trade execution 

services and, for some Participants, connectivity fees to access the SEF Trading System, as follows:

1. Transaction Fees: Transaction Fees will be charged on the basis of each Transaction, and

may vary depending on the tenor and currency pair of each Contract. Different pricing may

be charged depending on whether the Participant has acted in a “passive” or “removing”

capacity in connection with each such Transaction. In connection with each Transaction,

Cboe SEF systematically identifies each Participant counterparty as either passive or

aggressive (removing) and charges fees in respect of each such category of Participant

counterparty. Specifically, Cboe SEF identifies as “passive” the Participant counterparty

whose Order resided on the order book and subsequently matched against an inbound

Order, while Cboe SEF identifies as “aggressive” or “removing” the Participant counterparty

submitting such inbound Order.

2. Connectivity Fees: Participants may be charged connectivity fees to access the SEF Trading

System. Cboe SEF will charge Connectivity Fees for each physical connection a Participant

establishes with the SEF Trading System. Cboe SEF will not charge for connectivity via either

its Transatlantic or Transpacific point of presence. Cboe SEF will pass through all data center

cross-connect charges, if applicable. Cboe SEF may also charge fees on a per-session basis.

3. ISV Fees: In accordance with Rules 321 and 324, Participants may access the SEF Trading

System via a SEF ISV. ISV Fees incurred by Cboe SEF as a result of a Participant’s activity on

the SEF will be passed through to that Participant, as applicable.

4. Messaging Fees: Participants may use third-party vendors for post-trade messaging services. 

Messaging Fees incurred by Cboe SEF as a result of a Participant’s activity on the SEF will be 

passed through to that Participant, as applicable.

B. Description of the basis for all dues, fees, or other charges

There are two categories of Participants that can execute Transactions on Cboe SEF: A Trading Firm

may execute Transactions on behalf of and as agent of a Prime Broker; and a Principal Trading Firm

may execute Transactions on its own behalf. Cboe SEF charges Participants that are Trading Firms or

Principal Trading Firms a Fee for each Transaction executed on the SEF Trading System. The Fee is

based on the Notional Amount in USD of each Transaction and is charged as a dollar amount per USD 

million of Notional Amount. A minimum Transaction Fee of USD 1.00 per Transaction is also charged 

in respect of any Order submitted to the SEF Trading System.
Submission Date – December 15, 2022

Page B-2

Transaction Fees

Connectivity Fees

Physical Connectivity 

Pricing:

Bandwidth Installation Monthly Fee

1G and Below no charge $500.00 / connection

10G no charge $1,000.00 / connection

Transatlantic 

Connectivity (LD4 to 

NY5)

no charge Free

Transpacific 

Connectivity (TY3 to 

NY5)

no charge Free

Session Charges: Monthly Fee

FIX Order Entry Free

FIX BookFeed 

(Market Data)

Free

ITCH Free

ISV Fees – Pass Through 

Messaging Fees – Pass Through 

Currency Pair Tenor Passive Fee 

(in USD, per USD 1mm of 

Notional Amount)

Removing (Aggressing) Fee

(in USD, per USD 1mm of 

Notional Amount)

All All 5.00 10.00