refinitiv.com

An LSEG Business

June 8, 2023

SUBMITTED VIA CFTC PORTAL 

Mr. Christopher J. Kirkpatrick

Office of the Secretariat 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

Re: Submission 23-01: Refinitiv US SEF LLC – Extension of RFS Fee Waiver Incentive 

Dear Mr. Kirkpatrick: 

Pursuant to Commodity Futures Trading Commission (the “CFTC”) Regulation §40.6(a), Refinitiv US SEF 

LLC (“RSEF”), a swap execution facility registered with the CFTC is submitting for self-certification an 

extension to its Request for Stream Incentive Program (“RFS Fee Waiver Incentive”) through December 

31st, 2023 (“Proposed Rule Change”). The RFS Fee Waiver Incentive was originally submitted to the 

CFTC on May 2nd, 2022, and then subsequently extended for another 6 months on December 12, 2022. 

The proposed rule change will take effect on July 1st, 2023, and run through December 31st, 2023. No 

other material changes to the RFS Fee Waiver Incentive will be made. 

Part I: Explanation and Analysis

RSEF offers an RFS platform, through which RSEF Participants can request a continuous stream of 

quotes from other RSEF Participants. RSEF has decided to extend its RFS Fee Waiver Incentive by six 

months to encourage Participants on RSEF to use the Request for Stream execution mechanism for 

trading their non-deliverable forwards. 

Part II: Description of Rule Changes

The previous RFS Fee Waiver Incentive was set to expire June 30, 2023. RSEF is proposing to extend 

the RFS Fee Waiver Incentive by six months through December 31, 2023.

Part III: Core Principle Compliance 

RSEF reviewed the Proposed Rule Change against the requirements of the SEF Core Principles contained 

in Part 37 of the CFTC’s regulations and finds it will continue to comply with all requirements and standards 

set forth therein. Specifically, this rule change has potential relevance to Core Principle 2 (Compliance 

with Rules). The changes described in this filing ensure RSEF meets the objectives of Core Principle 2, 

including that, in accordance with CFTC Regulation §37.200, RSEF has established rules governing the 

operation of RSEF, specifically any applicable fees. RSEF considered its rule compliance requirements 

and believes including the Proposed Rule Change in its rules maintains compliance with Core Principle 2.
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Part IV: Public Information 

RSEF has posted a notice of pending certification with the CFTC and a copy of the submission on RSEF’s 

website at: https://www.refinitiv.com/en/products/sef-swap-execution-facility.

Part V: Opposing Views

There were no opposing views expressed to RSEF by its governing board or committee members, or 

market participants.

Certification

RSEF hereby certifies to the CFTC, pursuant to the procedures set forth in CFTC Regulation §40.6, that 

the attached submission complies with the Commodity Exchange Act, as amended, and the regulations 

promulgated thereunder. 

Should you have any questions, please do not hesitate to contact me at stephanie.feldt@lseg.com or 

(551) 815-2465

Sincerely, 

Stephanie Feldt

Chief Compliance Officer

cc: Nancy Markowitz, Deputy Director, Division of Market Oversight, Market Review Branch

Marilee Dahlman, Special Counsel, Division of Market Oversight (Commodity

Futures Trading Commission)