Maria Alarcon

Manager, Legal June 27, 2022

Re: Changes to ICC Rules to Provide for 

Clearance of Additional CDS Contracts 

Pursuant to Section 5c(c)(1) of the 

Commodity Exchange Act and Commission 

Regulation 40.6

VIA ELECTRONIC PORTAL

Mr. Christopher Kirkpatrick

Secretary

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, D.C. 20581

Dear Mr. Kirkpatrick:

ICE Clear Credit LLC (“ICC”) hereby submits, pursuant to Section 5c(c)(1) of the Commodity Exchange Act 

and Commodity Futures Trading Commission (“Commission”) Regulation 40.6, a self-certification of 

changes to the ICC Rulebook (the “Rules”) to provide for the clearance of additional Standard Emerging 

Market Sovereign CDS contracts (collectively, the “EM Contracts”). ICC is registered with the Commission 

as a derivatives clearing organization (“DCO”). ICC intends to make the amended Rules effective no sooner 

than the tenth business day following the filing of this submission with the Commission at its Washington, 

D.C. headquarters and with its Chicago regional office.

This submission includes the amended Rules. A description of the principal changes contained in the 

amended Rules follows. Certification of the amended Rules pursuant to Section 5c(c)(1) of the Act and 

Commission Regulation 40.6 is also provided below.

The purpose of the proposed rule change is to adopt rules that will provide the basis for ICC to clear 

additional credit default swap contracts. ICC believes the addition of these contracts will benefit the market 

for credit default swaps by providing market participants the benefits of clearing, including reduction in 

counterparty risk and safeguarding of margin assets pursuant to clearing house rules. Clearing of the 

additional EM Contracts will not require any changes to ICC’s risk management framework.

ICC proposes amending Subchapter 26D of its Rules to provide for the clearance of additional EM 

Contracts, specifically the Arab Republic of Egypt, Kingdom of Bahrain, and Sultanate of Oman. These 

additional EM Contracts have terms consistent with the other EM Contracts approved for clearing at ICC 

and governed by Subchapter 26D of the Rules. Minor revisions to Subchapter 26D (Standard Emerging 

Market Sovereign (“SES”) Single Name) are made to provide for clearing the additional EM Contracts. 

Specifically, in Rule 26D-102 (Definitions), “Eligible SES Reference Entities” is modified to include Arab 

Republic of Egypt, Kingdom of Bahrain, and Sultanate of Oman in the list of specific Eligible SES Reference 

Entities to be cleared by ICC.

Core Principle Review:

ICC reviewed the DCO core principles (“Core Principles”) as set forth in the Commodity Exchange Act. 

During this review, ICC identified the following Core Principles as being impacted:

Participant and Product Eligibility: ICC has set appropriate standards in ICC’s policies and procedures for 

determining the eligibility of contracts. The additional EM Contracts fulfill ICC’s standards regarding product 

eligibility. 
2

Risk Management: ICC will apply its established margin and pricing methodology to the additional EM 

Contracts.

Settlement Procedures: The additional EM Contracts are subject to ICC’s current physical settlement rules 

under Chapter 22: CDS Physical Settlement. 

Amended Rules:

The proposed change consists of revisions to Chapter 26 of the ICC Rules to provide for the clearance of 

the additional EM Contracts. 

Annexed as an Exhibit hereto is the following:

A. Proposed amendments to the ICC Rules

Certifications:

ICC hereby certifies that the amended Rules comply with the Act and the regulations thereunder. There 

were no substantive opposing views to the rules.

ICC certifies that, concurrent with this filing, a copy of the submission was posted on ICC’s website, which 

may be accessed at: https://www.theice.com/clear-credit/regulation

ICC would be pleased to respond to any questions the Commission or the staff may have regarding this 

submission. Please direct any questions or requests for information to the attention of the undersigned at 

(312) 836-6854.

Sincerely,

Maria Alarcon

Manager, Legal