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

New York, NY 10022 bloombergsef.com 

August 14, 2023 

Submitted via Portal

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: CFTC Regulation 40.6(a) Certification. Issuance of BSEF Notice to Participants 2023-R-11

(Correcting Trades and Offsetting Trades)

Ladies and Gentlemen: 

Bloomberg SEF LLC (“Bloomberg SEF”) is certifying to the U.S. Commodity Futures TradingCommission

(“CFTC” or “Commission”)the (i) issuance of BSEF Notice to Participants 2023-R-11 regarding Rule 516.A

of the Rulebook and (ii) withdrawal of Notice to Participants 2016-8 has beenwithdrawn (“Notice”). 

The Rule Amendment is effective on August 28, 2023. A copy of the Notice is attached as Exhibit A. 

Bloomberg SEF reviewed the swap execution facility core principles (“Core Principles”) as set forth in the

Commodity Exchange Act (“Act” or “CEA”) and CFTC Regulations and identified that the amendment of

terms in Rule 516.A may have some bearing on the followingCFTC Regulations and Core Principles:

• CFTC Regulation 37.9 Methods of Execution for required and Permitted Transactions: Notice

2023-R-11 provides guidance regarding execution protocols for Correcting Trades and Offsetting

Trades.

• Monitoring of Trading and Trade Processing (Core Principle 4): Notice to Participants 2023-R-11

provides guidance for Participants on the regulatory requirements intended for Offsetting 

Trades and Correcting Trades. It is intended to assist Participants with remaining in compliance

with Rule 516.A.

• Availability of General Information(Core Principle 7): Bloomberg SEF will make publicly

available the details of the delisting by publishing this submission on Bloomberg SEF’s website.

Pursuant to Section 5c(c) of the Act and CFTC Regulations 40.6(a), Bloomberg SEF hereby certifies that 

the Rule Amendments comply with the Act, including all regulations thereunder. There were no 

substantive opposing views to the proposal.

Bloomberg SEF certifies that this submission has been concurrently posted on the BSEF website at 

https://www.bloomberg.com/professional/product/sef-compliance/. Please contact the undersigned at 

(212) 617-7331 with any questions regarding this matter.
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Bloomberg SEF LLC

731 Lexington Avenue

New York, NY 10022

Enclosure
Exhibit A
Bloomberg SEF LLC

Notice to Participants 2023-R-11

Bloomberg SEF Rule 516.A: Notificationof Action Taken and Trade Review-Cleared Swaps

This Notice to Participants 2023-R-11 supersedesNotice to Participants 2016-8 and Notice to

Participants 2020-1.

An Error Trade executed on BSEF on a non-anonymous basis can be corrected by Participants as set

forth in BSEF Rule 516.A, by using RFQT to send an RFQ to the other Participant affected by the Error

Trade and indicating that the potentialtrade is “Correcting Trade” or “Offsetting Trade.”

UsingRFQT with the “Correcting Trade” or “Offsetting Trade” indicators will constitute notice to the

Compliance Department andwill grant BSEF’s permission to the Participants to execute an Offsetting

Trade and/or Correcting Trade, subject to ex post facto review by the Compliance Department as set

forth in Rule 516.A(a)(ii). Bloomberg SEF will provide “Correcting Trade” or “Offsetting Trade” indicators

to a Recipient Participant in the RFQT message.

Upon request of the Compliance Department, a Participant shall provide details sufficient to identify the

Error Trade (e.g., UTI, FIT/FITDNA key, or Swap contract, notional amount, price/spread, Clearing House, 

and execution time). 

Participants can pre-arrange an Offsetting Trade and/or Correcting Trade in accordance with Rule 531.B.

“Correcting Trade” or “Offsetting Trade” indicators must be provided with an RFQ foran Offsetting

Trade or Correcting Trade regardless of whether the Offsetting Trade and/or Correcting Trade is a 

Required Transaction. Failure to provide the Correcting Trade or Offsetting Trade indicators forany

Offsetting Trade or Correcting Trade, including trades that are Permitted Transactions, will constitute a

violation of Rule 516.A.

Participants should be aware that Bloomberg SEF makes available the Correcting Trade and Offsetting

Trade indicators in the trading message APIsentto liquidity providers.

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

Bloomberg SEF Rulebook. 

Effective Date:August 28, 2023 

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