1

Registered name: ICE Clear Europe Limited, (Registered in England, No. 06219884)

Registered office: Milton Gate, 60 Chiswell Street, London EC1Y 4SA, United Kingdom

ICE Clear Europe Ltd is a recognised clearing house under the Financial Services and Markets Act 2000 and is supervised by the 

Bank of England.

January 19, 2024

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: ICE Clear Europe Self-Certification Pursuant to Commission Rule Rule 40.6 

– Model Risk Policy Amendments 

Dear Mr. Kirkpatrick:

ICE Clear Europe Limited (“ICE Clear Europe” or the “Clearing House”), a registered 

derivatives clearing organization under the Commodity Exchange Act, as amended (the 

“Act”), hereby submits to the Commodity Futures Trading Commission (the 

“Commission”), pursuant to Commission Rule 40.6 for self-certification, amendments 

to its Model Risk Policy (the “Policy”).

1 The amendments will become effective on the 

first business day following the tenth business day after submission, or such later date 

as ICE Clear Europe may determine. 

Concise Explanation and Analysis

ICE Clear Europe is updating its Model Risk Policy to clarify that the timeframe for revalidation of existing models is at least annually. Additionally, the amendments will 

update the Policy to allow for the President (in consultation with the Head of Risk and 

Chief Risk Officer, or if unavailable their delegates) to override elements of the Policy 

if it is deemed to be in the risk management interest of the Clearing House or important 

for market stability. If the President takes such actions, the amendments require that the 

Board be notified as soon as practicable. This will allow for ICEU to respond to 

unexpected situations in a timely manner while maintaining appropriate governance 

oversight. 

Compliance with the Act and CFTC Regulations

The amendments to the Model Risk Policy are potentially relevant to the following core 

principles: (D) Risk Management and (O) Governance, and the applicable regulations 

of the Commission thereunder.

1 Capitalized terms used but not defined herein have the meanings specified in the Model Risk Policy

or, if not defined therein, the ICE Clear Europe Clearing Rules. 
2

Registered name: ICE Clear Europe Limited, (Registered in England, No. 06219884)

Registered office: Milton Gate, 60 Chiswell Street, London EC1Y 4SA, United Kingdom

ICE Clear Europe Ltd is a recognised clearing house under the Financial Services and Markets Act 2000 and is supervised by the 

Bank of England.

• Risk Management. The amendments to the Policy are designed to enhance 

risk management related to models used by the Clearing House. The 

amendments clarify the timing for re-validation of models. Furthermore, the 

amendments to the Policy will address situations where deviations from the 

Policy may be needed for risk management purposes or to further market 

stability. The amendments thus enhance the Clearing House’s overall risk 

management, consistent with the requirements of Core Principle D and CFTC 

Rule 39.13.

• Governance. As discussed above, the amendments to the Policy would clarify 

the authority of the Clearing House’s President to make certain deviations 

from the Policy to address unexpected risk events, in consultation with the 

Head of Risk and Chief Risk Officer. The amendments would also clarify the 

role of the Board in such situations. In ICE Clear Europe’s view, the 

amendments are therefore consistent with the requirements of Core Principle 

O and CFTC Rule 39.24

As set forth herein, the amendments consist of the amendments to the Model Risk 

Policy. ICE Clear Europe has requested confidential treatment with respect to the 

amendments, which have been submitted concurrently with this self-certification 

submission. 

ICE Clear Europe hereby certifies that the amendments comply with the Act and the 

Commission’s regulations thereunder. 

ICE Clear Europe received no substantive opposing views in relation to the 

amendments.

ICE Clear Europe has posted a notice of pending certification and a copy of this 

submission on its website concurrent with the filing of this submission. 

If you or your staff should have any questions or comments or require further 

information regarding this submission, please do not hesitate to contact the undersigned 

at George.milton@theice.com or +44 20 7429 4564. 

Very truly yours,

George Milton

Head of Regulation & Compliance