SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 22-250

Organization: NEX SEF Limited ("NEX SEF")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 06/14/22 Filing Description: Amendments to NEX SEF Limited 

Form SEF Exhibits for Migration to the CME Globex Electronic Trading Platform and 

General NEX SEF/CME Group Integration (Phase II)

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: See filing.

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

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 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

1

Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

June 14, 2022

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: CFTC Regulation 40.6(a) Certification. Amendments to NEX SEF Limited 

Form SEF Exhibits for Migration to the CME Globex Electronic Trading 

Platform and General NEX SEF/CME Group Integration (Phase II).

NEX SEF Submission No. 22-250

Dear Mr. Kirkpatrick:

Pursuant to Commodity Futures Trading Commission (“CFTC” or “Commission”) Regulation 40.6(a), NEX 

SEF Limited (“NEX SEF”) hereby certifies to the Commodity Futures Trading Commission (“CFTC” or 

“Commission”) regarding Phase II of amendments to NEX SEF Form SEF Exhibits for migration to the 

CME Globex electronic trading platform (“CME Globex”) and general NEX SEF/CME Group integration 

effective on trade date June 30, 2022 (collectively, the “Rule Amendments”) as outlined below. The initial 

phase of the amendments may be viewed in NEX SEF Submission No. 20-066R dated March 8, 2022

(the “Initial Amendments”).

Specifically, NEX SEF is amending:

1. Exhibit L – to be consistent with the Initial Amendments for consistency with CME Group trade 

practice and enforcement rules;

2. Exhibits O-1 through O3 - which are audit trail review, surveillance and trade practice review 

procedures, are being updated to reflect NEX SEF migration to CME Globex as well as minor 

administrative changes;

3. Exhibits P and R - to reference the updated trade practice and enforcement rules in the Facility 

Rulebook; and

4. Exhibit Q –to be consistent with and reference the EBS Functionality Protocol changes in Facility 

Rulebook Chapter 9.

NEX SEF reviewed the Swap Execution Facility core principles (“Core Principles”) as set forth in the 

Commodity Exchange Act (“CEA” or “Act”) and identified that the Rule Amendments may have some 

bearing on the following Core Principles:

• Core Principle 2 – Compliance with Rules: As a result of the changes to the composition to 

the Board and other similar changes, the Rule Amendments are being implemented to remain in 

satisfaction of this Core Principle. 

• Core Principle 4 – Monitoring of Trade and Trade Processing: As a result of the changes to 

the composition of the Board, the Rule Amendments are being implemented to remain in 

satisfaction of this Core Principle. 
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

2

Pursuant to Section 5c(c) of the Commodity Exchange Act (the “Act”) and Regulations 37.3(b)3 and 40.6(a), 

NEX SEF hereby certifies that the Rule Amendments comply with the Act, as amended, and the 

Commission’s regulations thereunder. There were no substantive opposing views to this proposal.

Pursuant to Commission Regulation 37.3(b)(3), once a SEF is registered as such with the Commission, 

any amendments to Form SEF must be filed as a submission under part 40 of the Commission’s 

regulations or as otherwise specified by the Commission.1 The Rule Amendments serve to amend 

previous NEX SEF submissions. 

Attachments 1 through 7 are provided in blackline format under separate cover (confidential treatment 

requested).

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-

299-2200 or via email at CMEGSubmissionInquiry@cmegroup.com.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel

Attachments: 

1. Exhibit L – Analysis of Compliance with Core Principles (blackline format) (confidential treatment 

requested)

2. Exhibit O1 – NEX SEF Audit Trail Recordkeeping Program (blackline format) (confidential 

treatment requested)

3. Exhibit O2 – NEX SEF Surveillance Procedures (blackline format) (confidential treatment 

requested)

4. Exhibit O3 – NEX SEF Trade Practice Review Procedures (blackline format) (confidential 

treatment requested)

5. Exhibit P – Disciplinary Protocols (blackline format) (confidential treatment requested)

6. Exhibit Q – SEF Trading System and Platform (blackline format) (confidential treatment 

requested)

7. Exhibit R – Rules Prohibiting Trade Practice Violations (blackline format) (confidential treatment 

requested) 

1 See 78 Fed. Reg. 33476, at 33485 (June 4, 2013).
3

Attachments 1 through 7

(CONFIDENTIAL TREATMENT REQUESTED)

(ATTACHED UNDER SEPARATE COVER)