SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 20-325

Organization: NEX SEF LIMITED ("NEX SEF")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): July 17, 2020 Filing Description: Modifications to the NEX SEF 

Fee Schedule

SPECIFY FILING TYPE 

Please note only ONE choice allowed per Submission.

Organization Rules and Rule Amendments

Certification § 40.6(a)

Approval § 40.5(a)

Notification § 40.6(d)

Advance Notice of SIDCO Rule Change § 40.10(a)

SIDCO Emergency Rule Change § 40.10(h)

Rule Numbers: N/A

New Product Please note only ONE product per Submission.

Certification § 40.2(a) 

Certification Security Futures § 41.23(a)

Certification Swap Class § 40.2(d)

Approval § 40.3(a)

Approval Security Futures § 41.23(b)

Novel Derivative Product Notification § 40.12(a)

Swap Submission § 39.5

Official Product Name: 

Product Terms and Conditions (product related Rules and Rule Amendments)

Certification § 40.6(a) 

Certification Made Available to Trade Determination § 40.6(a)

Certification Security Futures § 41.24(a)

Delisting (No Open Interest) § 40.6(a) 

Approval § 40.5(a)

Approval Made Available to Trade Determination § 40.5(a)

Approval Security Futures § 41.24(c)

Approval Amendments to enumerated agricultural products § 40.4(a), § 40.5(a)

“Non-Material Agricultural Rule Change” § 40.4(b)(5)

Notification § 40.6(d)

Official Name(s) of Product(s) Affected: 

Rule Numbers: 
300 Vesey Street New York, NY 10282 T 212 521 4609 nirup.ramalingam@cmegroup.com cmegroup.com

1

Nirup Ramalingam

Chief Operating Officer

NEX SEF LIMITED

July 17, 2020

VIA ELECTRONIC PORTAL

Division of Market Oversight

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Modifications to the NEX SEF Fee Schedule

NEX SEF Submission No. 20-325

To Whom It May Concern:

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 (“CFTC” or “Commission”), NEX SEF Limited (“NEX SEF”) hereby notifies 

the Commission of modifications to NEX SEF’s fee schedule and certain incentive programs (“Fee Schedule”). The 

modifications to the Fee Schedule will be effective on August 1, 2020.

The Fee Schedule has been revised to renew certain discount and incentive programs. The modified Fee Schedule is

set forth in Appendix A below, with additions underlined and deletions overstruck. A clean version of the modified Fee 

Schedule is set forth in Appendix B below. A request for confidential treatment of the Fee Schedule is being 

simultaneously submitted to the Commission and a copy of that request for confidential treatment is included with this 

submission.

NEX 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 in an impartial, fair, and nondiscriminatory manner, and the Fee Schedule will be made transparent to all participants. In compliance with Core 

Principle 2 and Commission Regulation 37.200, the Fee Schedule does not incentivize manipulative trading or market 

abuse or impact NEX SEF’s ability to perform its trade practice and market surveillance obligations under the Act, and 

Market Regulation staff will continue to monitor trading 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. NEX SEF has implemented systems to track Fee Schedule participants’ 

transactions to ensure proper fee discounts are applied.

NEX SEF certifies that the revised Fee Schedule complies with the requirements of the CEA and the rules and 

regulations promulgated thereunder. There were no substantive opposing views to this proposal. 

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

http://www.cmegroup.com/market-regulation/rule-filings.html.

If you require any additional information regarding this submission, please contact the undersigned at 212-521-4609 or 

via email at CMEGSubmissionInquiry@cmegroup.com.

Sincerely,

/s/ Nirup Ramalingam

Chief Operating Officer

Attachments: Appendix A – NEX SEF Fee Schedule (blacklined) (Confidential Treatment Requested)

Appendix B – NEX SEF Fee Schedule (clean) (Confidential Treatment Requested)
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APPENDIX A

CONFIDENTIAL TREATMENT REQUESTED

(ATTACHED UNDER SEPARATE COVER)
3

APPENDIX B

CONFIDENTIAL TREATMENT REQUESTED

(ATTACHED UNDER SEPARATE COVER)