ACTIVE 255638570

ICAP Global Derivatives Limited 

2 Broadgate 

London 

United Kingdom 

EC2M 7UR 

March 26, 2020 

By CFTC 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: ICAP Global Derivatives Limited – Regulation 40.6(a) Rule Certification – Notice 

to Participants (IGDL-2020-R-2)

Dear Mr. Kirkpatrick: 

Pursuant to Section 5c(c) of the Commodity Exchange Act, as amended (the “Act”), and Section 

40.6(a) of the regulations of the Commodity Futures Trading Commission (the “Commission” or 

“CFTC”), ICAP Global Derivatives Limited (“IGDL”), a registered swap execution facility, hereby 

notifies the Commission that it will release the Market Regulation Advisory Notice attached 

hereto as Exhibit A (the “MRAN”) on March 26, 2020.

The MRAN relates to the guidance included in a series of no-action letters released by the 

Divisions of Swap Dealer and Intermediary Oversight (DSIO) and Market Oversight (DMO) of 

the CFTC in response to the global COVID-19 pandemic, and informs IGDL’s Participants and 

Customers that, until June 30, 2020, it will not enforce certain recordkeeping rules against any 

person subject to its jurisdiction solely for such person’s failure to comply with such 

recordkeeping requirements, provided that such person is relying on, and in compliance with the 

terms and conditions of, one of the applicable no-action letters. The MRAN will become effective 

on April 9, 2020. 

IGDL hereby certifies that: (i) the MRAN complies with the requirements of the Act and 

Commission regulations thereunder, and (ii) a notice and copy of this submission is being 

concurrently posted on IGDL’s website and may be accessed at: http://www.icap.com/what-wedo/global-broking/sef.aspx. IGDL is not aware of any substantive opposing views expressed 

with respect to this filing. 
Mr. Christopher J. Kirkpatrick 

March 26, 2020 

Page 2 

ACTIVE 255638570

Please contact Brian D. Donnelly, Chief Compliance Officer, at (201) 984-6956 or by email at 

bddonnelly@tullettprebon.com with any questions regarding this matter. 

Very truly yours, 

ICAP Global Derivatives Limited 

By: _______________________ 

Name: Brian D. Donnelly 

Title: Chief Compliance Officer 

Date: March 26, 2020 

Enclosures 

cc: CFTC Division of Market Oversight (dmosubmissions@cftc.gov) 

Nancy Markowitz, CFTC (nmarkowitz@cftc.gov) 
Mr. Christopher J. Kirkpatrick 

March 26, 2020 

ACTIVE 255638570

EXHIBIT A 

Notice to Participants 
From ICAP Global Derivatives Ltd. (IGDL) 

To All IGDL Participants and Customers 

Subject Enforcement of Specified IGDL Recordkeeping 

Rules for Persons Relying on CFTC COVID-19 

No-Action Relief 

Rule References 208(a) 

Notice Date March 26, 2020 

Effective Date April 9, 2020 

Notice Number MRAN 2020-01 

 

On March 17, 2020, in response to the global COVID-19 pandemic, the Divisions of Swap Dealer and 

Intermediary Oversight (DSIO) and Market Oversight (DMO) of the U.S. Commodity Futures Trading 

Commission (CFTC) released a series of no-action letters (each, a COVID-19 No-Action Letter) providing

temporary, targeted relief to certain CFTC-registered entities and members of CFTC-regulated swap execution 

facilities not registered or required to be registered with the CFTC in any capacity. These no-action letters 

include, among other things, relief from certain recordkeeping requirements that may be applicable to 

Participants and other persons subject to the jurisdiction of IGDL, a CFTC-registered swap execution facility. 

IGDL hereby notifies its Participants and Customers that until June 30, 2020, it will not enforce its Rule 208(a) 

against any person subject to its jurisdiction solely for such person’s failure to comply with any requirement to 

(i) make and keep records of oral communications pursuant to CFTC Regulation 1.35 or CFTC Regulation 

23.202, or (ii) record the date and time by time-stamp or other timing device pursuant to CFTC Regulation 1.35 

or CFTC Regulation 23.202 (collectively, the “Specified Recordkeeping Requirements”), provided that such 

Person is relying on, and in compliance with the terms and conditions of, an applicable COVID-19 No-Action 

Letter dated March 17, 2020 relating to compliance with the Specified Recordkeeping Requirements. 

Capitalized terms used but not defined herein shall have the meaning ascribed to them in the Rulebook.

For questions regarding this Market Regulation Advisory Notice, please contact: 

Brian Donnelly, Chief Compliance Officer +1 201 984 6956 or bddonnelly@tullettprebon.com

IGDL Market Regulation Advisory Notice

Contact

ACTIVE 255606507