360 Trading Networks, Inc. ∙ 521 Fifth Avenue, 38th Floor ∙ New York, NY 10175

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360 Trading Networks, Inc.

521 Fifth Avenue, 38th Floor 

New York, NY 10175

Phone: +1 212 776 2900

Fax: +1 212 776 2902

E-Mail: info@360t.com

www.360t.com

November 25, 2015

BY ELECTRONIC MAIL (submissions@cftc.gov)

Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Regulation 40.6(a) Rule Certification

360 Trading Networks Inc. Rulebook and User Guides Amendments

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c) of the Commodity Exchange Act (the “Act”) and Section 40.6(a) of 

the Regulations of the Commodity Futures Trading Commission (the “Commission”), 360 

Trading Networks Inc. (“360T”) hereby files the attached amendments to its Rulebook and User 

Guides. The Rulebook and User Guides have been amended in response to Commission staff 

guidance and comments and questions received from users and potential users of 360T. The

amended Rulebook and User Guides will become effective on December 10, 2015.

A concise explanation and analysis of the amendments to the Rulebook and User Guides and 

their compliance with applicable provisions of the Act, including Core Principles, and the 

Commission’s Regulations thereunder, is attached hereto as Exhibit A. A clean copy of the 

amended Rulebook is attached hereto as Exhibit B, and a copy of the Rulebook marked to show 

changes against the version submitted to the Commission on September 30, 2015 is attached 

hereto as Exhibit C. Clean and marked copies of the User Guide for Market Takers is attached 

as Exhibit D and Exhibit E, respectively. Clean and marked copies of the User Guide for 

Market Makers is attached as Exhibit F and Exhibit G, respectively.

360T hereby certifies that: (i) the amended Rulebook and User Guides comply with the Act and 

the Commission’s regulations thereunder; and (ii) a notice and copy of this submission is being 

concurrently posted on 360T’s web site. There were no substantive opposing views to the 

amendments.
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Please contact the undersigned at 44 020 3508 6344 or martin.oakley@360t.com if you have 

any questions or you would otherwise like to discuss this further.

Sincerely,

/s/ Martin Oakley

Chief Compliance Officer

Enclosure
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Exhibit A

Summary of Rulebook Changes: The 360T Rulebook has been amended in response to 

Commission staff guidance and comments and questions received from users and potential users 

of 360T. A clean copy of the amended Rulebook is attached hereto as Exhibit B; a copy of the 

Rulebook marked to show changes against the version submitted to the Commission on 

September 30, 2015 is attached hereto as Exhibit C.

Capitalized terms used but not defined herein have the meanings assigned to them in the 

Rulebook.

Rule Explanation

Core Principle or other 

CEA Provision, 

Commission Regulation 

and/or Commission 

Staff Letter

Cover Page Updates effective date. Regulation 40.6

Table of Contents Updates table of contents to reflect changes 

listed below.

See below

Rule 101 (“Authorized 

User”)

Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 101 (“Block 

Trade”)

Per Commission staff guidance, 360T has 

removed certain references to Block Trades.

Core Principle 1

Rule 101 (“Cleared 

Swap”)

Per Commission staff guidance, 360T has 

removed certain references to Cleared 

Swaps.

Core Principle 1

Rule 101 (“Clearing 

Firm”)

Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 101 

(“Emergency”)

Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 101 (“Package 

Transaction”)

Per Commission staff guidance, 360T has 

removed certain references to Package 

Transactions.

Core Principle 1

Rule 101 (“Risk-Based 

Limits”)

Per Commission staff guidance, 360T has 

removed certain references to Risk-Based 

Core Principle 1
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Limits.

Rule 101 

(“Termination Event”)

Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 201(c) Provides that the Board’s membership fairly 

represents the diversity of interests at 360T, 

including the interests of banks, futures 

commission merchants, corporate treasury 

departments, institutional traders and asset 

managers that trade on the Trading System, 

as appropriate.

Regulation 1.64

Rule 302(a) Per Commission staff guidance, 360T has 

removed certain references to self-clearing 

Participants and Clearing Firms.

Core Principle 1

Rule 305 Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 307 Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 310(d) Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 401(a)(8) Clarifies that records must be kept as 

required by Applicable Law, including, but 

not limited to, Commission Regulations 1.31 

and 1.35.

Regulations 1.31 and 

1.35

Rule 406 Provides that any market participant that is 

not already subject to Rule 401(a)(8) and that 

conducts substantial trading on the Trading 

System shall keep, or cause to be kept, 

complete and accurate books and records, 

including but not limited to records of its 

trading in Swaps, in the instruments 

underlying any such Swaps or in any 

instrument or index used as a reference price 

for a Swap, or in any related derivatives 

markets, for at least five years and make such

books and records available to 360T, the 

Regulatory Services Provider and the 

Regulation 37.404(b)
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Commission in accordance with Applicable 

Law. For purposes of this provision, 

“substantial trading” shall be determined by 

360T its sole discretion upon prior written 

notice, taking into consideration the market 

participant’s average daily trading volume 

and open interest for one or more Swaps 

effected on or pursuant to the Rules.

Rule 510 Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 520(c) Removes reference to certain suspense 

accounts.

Core Principle 1

Rule 520(d) Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 521(a) Clarifies that 360T shall establish, as is 

necessary or appropriate, position limits for 

one or more Swaps to reduce the potential 

threat of market manipulation or congestion.

Core Principle 6

Regulation 37.600

Rule 521(d) Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 521(h) Clarifies that 360T demonstrates compliance 

with Commission Regulation 37.600 by 

sending the Commission a list of Permitted 

Transactions traded on or pursuant to the 

Rules.

Core Principle 6

Regulations 37.600 and 

37.601

Appendix B to Part 37

Rule 522(a) Clarifies that 360T shall establish, as is 

necessary or appropriate, position 

accountability levels for one or more Swaps 

to reduce the potential threat of market 

manipulation or congestion.

Core Principle 6

Regulation 37.600

Rule 524(a) Provides that 360T supports Permitted 

Transactions only.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 524(c) Per Commission staff guidance, 360T has Core Principle 1
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removed the RFQ requirements related to 

Required Transactions.

Rule 524(d) Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Rule 525(d) Clarifies that all Participants must maintain 

all Terms Incorporated by Reference in 

accordance with Commission Letter No. 15-

25, which expires on March 31, 2016.

Letter No. 15-25

Rule 526(a) (former) Per Commission staff guidance, 360T has 

removed the Rules related to Swaps that are 

not accepted for clearing.

Core Principle 1

Rule 526(a)(1) Clarifies that the provisions of paragraph 

(a)(1) supersede the other provisions of Rule 

526.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(a)(2) Provides that, in event that 360T determines 

to adjust trade prices or bust a trade in 

accordance with paragraph (a)(2), 360T may 

consider any relevant information, including, 

but not limited to, the last trade price of the 

Swap, a more recent price for a different 

maturity date, the price of the same or related 

Swap established in another venue or another 

market and the market conditions at the time 

of the trade.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(b)(1) Provides that 360T may review a central 

limit order book (“CLOB”) trade based upon 

a request by an Authorized Trader. This 

paragraph also has been revised to include a 

sub-header.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(b)(2) Inserts a sub-header. N/A

Rule 526(b)(3) Provides that 360T will issue an alert to all 

Participants and Authorized Traders. This 

paragraph also has been revised to include a 

sub-header.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(b)(4) Renumbers the paragraph and renumbers the See below
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cross-reference to paragraph (g).

Rule 526(b)(5) Clarifies that 360T will issue an alert to all 

Participants and Authorized Traders. This 

paragraph also has been renumbered.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(b)(6) Removes the provision that provides that 

360T will issue a notice regarding 

cancellation as duplicative of new paragraph 

(b)(8). This paragraph also has been 

renumbered.

See below

Rule 526(b)(7) Renumbers the paragraph. See above

Rule 526(b)(8) Provides that a decision by 360T to adjust 

CLOB trade prices or bust a CLOB trade will 

be made as soon as practicable, and 360T 

will notify all Participants and Authorized 

Traders, the Swap Data Repository and, if 

applicable, the Derivatives Clearing 

Organization of any such decision.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(c)(1) Provides that 360T may determine to review 

an RFQ upon request by a Participant or 

Authorized Trader.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(c)(2) Provides that 360T will determine whether or 

not an RFQ will be subject to review. In the 

absence of a timely request for review, 

during volatile market conditions, upon the 

release of significant news, or in any other 

circumstance in which 360T deems it to be 

appropriate, 360T may determine, in its sole 

discretion, that an RFQ shall not be subject 

to review.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(c)(3) Provides that upon deciding to review an 

RFQ, 360T will promptly issue an alert to all 

affected Participants and/or Authorized 

Traders indicating that the trade is under 

review.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(c)(4) Provides that once 360T has agreed to place 

an RFQ under review, the Participant or 

Authorized Trader requesting to cancel or 

Core Principles 2 and 4

Regulations 37.200(c), 
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adjust the trade shall, where it has not done 

so already, confirm in writing to this effect. 

360T shall then request the other Participant 

or Authorized Trader involved in the RFQ to 

confirm in writing its willingness to cancel or 

adjust the trade.

37.201(a) and 

37.400(a)

Rule 526(c)(5) Provides that where the other Participant or 

Authorized Trader involved in the RFQ does 

not confirm in writing its willingness to 

cancel or adjust the trade, 360T shall issue an 

alert to all affected Participants and/or or 

Authorized Traders indicating that the trade 

shall stand. (As noted above, this provision 

is subject to paragraph (a).)

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(c)(6) Provides that where the other Participant or 

Authorized Trader involved in the RFQ 

confirms in writing its willingness to cancel 

or adjust the trade, 360T shall cancel or 

adjust the trade accordingly.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(c)(7) Provides that busted trade prices and any 

prices that have been adjusted shall be

cancelled in 360T’s official record of time 

and sales. Trades that are price–adjusted 

shall be inserted in the time and sales record 

at the adjusted trade price.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(c)(8) Provides that a decision by 360T to adjust 

RFQ trade prices or bust an RFQ will be 

made as soon as practicable, and 360T shall 

notify the affected Participants and/or 

Authorized Traders, the Swap Data 

Repository and, if applicable, the Derivatives 

Clearing Organization of any such decision.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Rule 526(d)-(i) Renumbers the paragraphs. See above

Rule 528(a) Clarifies that 360T will report Reportable 

Swap Data for each Swap executed on or 

pursuant to the Rules to a Swap Data 

Repository listed in paragraph (c) as soon as 

technologically practicable following 

execution. The relevant Swap Data 

Repository shall publicly disseminate the 

information in Appendix A to Part 43 of 

Commission Regulations in a consistent form 

Parts 43 and 45 of 

Commission 

Regulations
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and manner for Swaps within the same asset 

class.

Rule 528(b) Provides that if both counterparties to a Swap 

executed on or pursuant to the Rules are 

equal in the hierarchy set out in Commission 

Regulations, the Reporting Counterparty for 

such Swap shall be determined as follows:

(i) With respect to a non-deliverable 

forward, the Reporting Counterparty 

is the counterparty selling the 

currency that occurs first in the 

26‐letter English alphabet.

(ii) With respect to a foreign currency 

option, the Reporting Counterparty is 

the seller of the option.

Regulation 45.8

Rule 528(c) Provides that 360T has designated DTCC 

Data Repository (U.S.) LLC as the Swap 

Data Repository to which it will report 

Reportable Swap Data for each Swap 

executed on or pursuant to the Rules.

Core Principle 1

Rule 528(d) Clarifies that each Participant, Authorized 

Trader and Authorized User that enters an 

Order or a Request for Quote into the 

Trading System shall include with each such

Order or Request for Quote sufficient 

information to enable 360T to report all 

Reportable Swap Data pursuant to Parts 43 

and 45 of Commission Regulations.

Parts 43 and 45 of 

Commission 

Regulations

Rule 601 Per Commission staff guidance, 360T has 

removed certain references to Block Trades.

Core Principle 1

Rule 602 Per Commission staff guidance, 360T has 

removed certain references to Block Trades.

Core Principle 1

Rule 712(g) Fixes typographical error. N/A

Rule 713(b) Provides that 360T will provide a copy of a 

Disciplinary Panel’s order to the respondent 

not later than 30 days after the rendering of a 

final decision.

Regulations 9.11 and 

9.12

Rule 714(a) Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Core Principle 1
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Firms.

Rule 715(n) Provides that the Appeal Panel will issue a 

written decision and provide a copy to the 

parties not later than 30 days after the 

rendering of a final decision. The written 

decision will become effective no sooner 

than 15 days after written notice of the 

decision is delivered to the parties.

Regulations 9.11 and 

9.12

Rule 716(c) Provides a schedule listing the recommended 

summary fines.

Appendix B to Part 37

Rule 719 Provides that 360T will provide final written 

notice of a Disciplinary Proceeding through 

NFA’s Background Affiliation Status 

Information Center

Regulations 9.11 and 

9.12

Rule 905 Per Commission staff guidance, 360T has 

removed certain references to Clearing 

Firms.

Core Principle 1

Chapter 10 Per Commission staff guidance, 360T has 

removed certain references to Cleared Swaps 

and Clearing Firms.

Core Principle 1

Appendix 1 Inserts currency list that was certified by 

360T on September 30, 2013. In addition, 

the contract specifications were revised to 

reference Part 150 of Commission 

Regulations. The remaining changes are 

non-substantive.

Core Principle 3
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Summary of Changes to User Guide for Market Takers: The User Guide for Market Takers

has been amended in response to Commission staff guidance and comments and questions 

received from users and potential users of 360T. A clean copy of the User Guide for Market 

Takers is attached hereto as Exhibit D; a copy of the User Guide for Market Takers marked to 

show changes against the version submitted to the Commission on September 30, 2015 is 

attached hereto as Exhibit E.

Section Explanation

Core Principle or other 

CEA Provision, 

Commission Regulation 

and/or Commission 

Staff Letter

Section 1 Non-substantive changes N/A

Section 3.1 Provides additional clarity on the means by 

which a user may effect an NDF transaction.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 3.2 Provides additional clarity on the means by 

which a user may effect an NDS transaction.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 3.3 Provides additional clarity on the means by 

which a user may effect an FX options 

transaction.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 4 Removes references to Required 

Transactions. Additional changes are 

intended to better clarify the system’s 

functionality.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 5 Provides information related to special 

execution modes, including multiple 

executions and rollover and early settlement 

of trades.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 6 Changes Section number. Provides 

additional clarity on the means by which a 

user may effect an order book transaction. 

Removes reference to Commission 

Regulation 37.9.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)
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Section 7 Changes Section number. See above
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Summary of Changes to User Guide for Market Makers: The User Guide for Market Makers

has been amended in response to Commission staff guidance and comments and questions 

received from users and potential users of 360T. A clean copy of the User Guide for Market 

Makers is attached hereto as Exhibit F; a copy of the User Guide for Market Makers marked to

show changes against the version submitted to the Commission on September 30, 2015 is 

attached hereto as Exhibit G.

Section Explanation

Core Principle or other 

CEA Provision, 

Commission Regulation 

and/or Commission 

Staff Letter

Section 1 Non-substantive changes N/A

Section 3.2 Provides additional clarity on the means by 

which a user may effect an NDS transaction.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 3.3 Provides additional clarity on the means by 

which a user may effect an FX options 

transaction.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 5 Provides information related to special 

execution modes, including multiple 

executions and rollover and early settlement 

of trades.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 6 Changes Section number. Provides 

additional clarity on the means by which a 

user may effect an order book transaction. 

Removes reference to Commission 

Regulation 37.9.

Core Principles 2 and 4

Regulations 37.200(c), 

37.201(a) and 

37.400(a)

Section 7 Changes Section number. See above