Exhibit F

User Guide 360T SEF

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USER GUIDE 360T SEF

TEX MULTIDEALER TRADING SYSTEM

USER GUIDE 360T SWAP EXECUTION FACILITY 

FOR THE MARKET MAKER

27 SEPTEMBER, 2016

© 360 TREASURY SYSTEMS AG, 2015
User Guide 360T SEF

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1 INTRODUCTION

In July 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank” or 

the “Act”) was signed into U.S. federal law. The Act made changes to the financial regulatory 

environment in America as a way of promoting financial stability by, among other things, improving 

accountability and transparency in the financial system. Within the Act, Title VII concerns 

regulation of the over-the-counter swaps markets, which requires certain OTC derivative and FX 

instruments to be traded on a regulated SEF.

360 Trading Networks Inc. (360T) offers a SEF venue for such transactions captured under 

this definition. At present, this applies to FX options and FX non- deliverable forward and Swap 

(NDF and NDS) instruments traded by persons identified as U.S. entities or which fall under the 

definitions within the Act. 360T’s SEF services will enable clients to comply with their own Dodd 

Frank regulatory obligations and will retain the ability for clients to trade with greater transparency 

and enhanced control at every stage of the trading lifecycle.

Once a client is considered by 360T to be SEF relevant, users can only trade NDF, NDS and FX 

Options on the SEF. U.S. clients and entities trading with U.S. clients are blocked from trading 

these instruments if not enabled on the SEF. The required forms have therefore to be complete 

as well as the administrative information within the 360T administration tool.

This user manual describes the functionality available for the Market Participant trading as Market 

Maker under the 360T Swap Execution Facility (“360T SEF”). This means on one side the 

administrative functions to complete in the system prior to being able to trade under the 360T 

SEF, as well as the actual trading of the transactions falling under the regulation.

The 360T SEF platform is embedded in the 360T trading platform, so that an entity defined as 

trading NDF/NDS and FX Options under the SEF can still trade all other products under the non 

SEF platform. This user manual only describes the SEF relevant part. Please refer to the general 

360T user manuals for all non SEF business.

In the 360T trader user interface, SEF related items are either displayed in green color with “SEF” 

in superscript, or with the mention of “SEF” in brackets, as shown in the following screen captures.

A Swap Dealer who has signed the 360T SEF participation agreement can trade NDF, NDS and 

FX Options both under the SEF and under the non SEF platform. This happens implicitly over 

configuration settings on the platform, so that you as user don’t have to switch from SEF to non 

SEF.

Whether a trade is done under the SEF or not basically depends on the country of origin of the 

requesting entity and user and on the country of origin of the providing entity and user. US 

requesters can trade only with counterparties which have also signed the SEF participation 

agreement and set up the SEF reporting parameters. Non US requesters can trade with US and 

non US counterparties.

For the Market Maker this means the following:

If you are a Swap Dealer defined with 360T as a US participant, all NDF, NDS and FX Options 

will be traded on the SEF. You will be able to execute trades with US and non US requesters 

under the condition that you and the counterparties have recorded their reporting parameters.
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If you are a Swap Dealer defined with 360T as a non US participant, but you wish to execute 

trades with US counterparties on the SEF, you will have to record your SEF reporting parameters 

to be included in the bank basket of your clients. Trading with non US clients is off-SEF.

Requester Provider SEF / OFF SEF

Is US Person Is US Person SEF

Is not US Person SEF

Is not US Person Is US Person SEF

Is not US Person OFF SEF

In summary, for all cases marked as SEF above, the following prerequisites must be fulfilled:

- Company has provided 360T with its LEI

- Company is SEF enabled by 360T

- SEF Reporting parameters have been keyed in both for Company and Traders.
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2 SEF REPORTING PARAMETERS

Under the Dodd Frank Act regulation, required transaction creation data must be reported to a 

Swap Data Repository (SDR). In addition, data is reported to the National Futures Association 

(NFA) in order to conduct trade practice and market surveillance on behalf of the 360T SEF. The 

data transmitted to the SDR and the NFA are trade execution parameters as well as activity data 

in general about who is trading and what is trading. For this, some participant specific data needs 

to be completed by the company and users.

Once the SEF participation agreement has been signed with 360T, users will have been named 

to 360T’s support services and given the according Administration rights to complete required 

parameters.

The functionality “SEF Data” to enter the required data can then be found under the Administration 

menu.

Required fields are displayed in bold letters. As long as a field is shown in red color the data is 

incomplete and can’t be saved.

Each company and user set up by 360T’s services on the platform is already associated to a 

country. Depending on that information, some fields might not be required. For example, if you 

are a UK entity but have signed the SEF participation agreement in order to be able to trade with 

US participants, then you will not be required to enter a SSN.

Please note that if you are using an integrated price engine, the AutoDealer also needs SEF 

reporting data. It is assumed that it will be provided by the person responsible for the pricing 

system in the bank.

Once all data has been provided, your provider entity will automatically be included in the 

requester bank basket for an NDF, NDS or FX Option trade request of market takers having a 

counterparty relationship with you.

If the data is incomplete, the user will not be able to trade on the SEF.

After completion of the SEF User data form, a trader can be disabled from SEF trading by setting 

the value of the “SEF enabled” field to “false”. 

Note that disablement of SEF trading only takes effect after the trader logs out and back into the 

application.

Indication of Collateralization:

Pursuant to Part 45 of CFTC regulations, an indication of collateralization has to be reported to 

the SDR for all bilaterally executed swaps on the SEF and must include the following values:

- “uncollateralized”

- “partially collateralized”

- “one-way collateralized”

- “fully collateralized”
User Guide 360T SEF

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360T requires Market Makers to designate collateralization indication on a client by client basis. 

The corresponding configuration form is accessible via the “Collateralization” tab.

For clarification purposes, the configuration form is subdivided into three separate menus. Under 

the first menu point entitled “Defined”, the administrator has access to the list of clients for which 

the collateralization designation has been already configured. The “Undefined” menu provides 

an overview of missing values and, finally, “All” displays a consolidated list of both “Defined” and 

“Undefined” data. The collateralized designation can either be set per client on an individual basis 

or by use of the bulk functionality via the right-hand side mouse button.

After selecting the “Save” button, the amended entries are automatically re-located into the 

different sub-menus.
User Guide 360T SEF

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3 TRADING NDF/NDS AND FX OPTIONS AS REQUEST FOR STREAMED 

QUOTES ON THE SEF

Once SEF specific reporting data is defined, NDF, NDS and FX Options requests from 

Requesters that have also completed the SEF on-boarding can be received and priced by you.

3.1 NDF

Non deliverable forwards are outright contracts for non-convertible foreign currencies, which are 

cash-settled by using the difference between the agreed forward rate and the spot rate on the 

fixing date, which is usually 2 working days before the settlement date.

The workflow supported in 360T’s SEF only concerns the execution of the NDF. Once NDF will 

be subject to clearing, further information will be completed in this manual. The settlement of the 

NDF always takes place offline between the counterparties.

On the market taker side, an FX Non deliverable forward (NDF) product definition is opened after 

selecting the product NDF in the product selection area and after clicking on a price in one of the 

FX Live Pricing.

The product definition screen will already include predefined data corresponding to the selection 

in the live pricing screen. For example, the currency pair and the effective date correspond to 

that selection.

The market taker enters an NDF with the desired data, i.e. notional amount, tenor and or maturity 

date, fixing date and fixing reference.

3.2 NDS

Non-deliverable swaps traded on 360T SEF can be considered as two linked non-deliverable 

forwards with opposite actions.

The workflow supported in 360T’s SEF only concerns the execution of the NDS. Once NDF will 

be subject to clearing, further information will be completed in this manual. The settlement of the 

NDS always takes place offline between the counterparties.

The product definition screen will already include predefined data corresponding to the selection 

in the live pricing screen. For example, the currency pair and the effective periods correspond to 

that selection.

The market taker enters an NDS with the desired data, i.e. notional amount, tenor and or maturity 

date, fixing date and fixing reference.

In order to effect a transaction, a user must specify the relevant currencies and the notional 

amount to be traded. The minimum notional amount that can be specified is the relevant 

currency’s smallest monetary unit. The maximum notional amount is restricted to a fixed digit 

length determined by 360T based upon credit and market risk considerations. 360T may change 

these parameters at any time. Users can access these parameters through the Trading System.
User Guide 360T SEF

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The Fixing Date will automatically be populated by the Trading System based on the spot date 

convention of the relevant currencies, and is generally two days before the value date.

The Trading System will automatically send the requester’s RFQ to the liquidity providers selected 

in advance by the requester on a disclosed basis. There is no minimum or maximum number of 

liquidity providers to whom RFQs may be sent.

Different liquidity providers may be selected for different currencies. A requester can override this 

functionality if desired in order to select different liquidity providers on a trade by trade basis. 

Notification of execution is sent to be counterparties to a transaction, but is not sent to all users 

of the Trading System.

3.3 FX Options

360T supports requests in first generation options, calls and puts and combinations of 2 options 

(zero premium or standard risk reversal or a request with two legs), European and American style.

Option pricing can be requested for live pricing or with a separate spot delta hedge.

The premium value date is defaulted to the spot date for the currency in which the premium is to 

be paid, but can be changed by the user. The exercise date is automatically generated by the 

Trading System and is 1 or 2 business days before the relevant delivery expiration date, 

depending on the spot date convention for the relevant currency pair.

The minimum notional amount that can be specified is the relevant currency’s smallest monetary 

unit. The maximum notional amount is restricted to a fixed digit length determined by 360T based 

upon credit and market risk considerations. 360T may change these parameters at any time. 

Users can access these parameters through the Trading System.

The Trading System will automatically send the requester’s RFQ to the liquidity providers selected 

in advance by the requester on a disclosed basis. There is no minimum or maximum number of 

liquidity providers to whom RFQs may be sent.

Different providers may be selected for different currencies. A requester can override this 

functionality if desired in order to select different liquidity providers on a trade by trade basis. 

Notification of execution is sent to the counterparties to a transaction, but is not sent to all users 

of the Trading System.

3.3.1 FX Plain Vanilla/Risk Reversal / Zero Cost / Strategy option

In addition to plain vanilla, it is possible to request combinations of 2 options.

Pre-configured strategies to create a standard risk reversal or a zero-cost option are accessible 

over the menu Transaction.

To request a zero-premium option, the user requests the strike for the first option of the 

combination and the bank will quote the strike of the second option.

In case of a standard risk reversal, the user will request a given strike for both options and the 

bank will quote the premium, similar to plain vanilla options.
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Further freely configurable combinations of two plain vanilla options can be requested as Option 

Strategies. The product definition is similar to the risk reversal product definition, except that any 

combination of 2 options can be defined.
User Guide 360T SEF

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4 PRICING IN THE TRADER WORKSHEET

Once a product definition is complete, the requester clicks to Send to receive quote streams to 

the swap dealers defined in the provider list.

The following describes the workflow when the request is not routed to an automated pricing 

system but is published for manual pricing in 360T’s trader worksheet.

A trade request routed for manual intervention shows up as a blinking line with its details, while a 

ringing sound notifies the trader of the incoming request. To provide a price, the trader clicks on 

the request line to get the quoting screen.

4.1 Pricing NDF

The price of a NDF is the forward rate, which is calculated by the provided spot rate and forward 

points.

In case the user requests a two-way price, both bid rate (on the left side) and offer rate (on the 

right side) have to be provided.

Click to Send instantly shows the provided price to the requester in his competitive bidding screen, 

together with prices provided by other requested market makers, as well as with executable and 

indicative orders from the SEF Order Book.

Once the price is sent to the requester, the buttons Cancel and Send are replaced by the buttons 

Interrupt and Requote. You can withdraw your quote by clicking Interrupt. By Requote, you can 

directly send a newly entered quote.

In case the user executes your offered price, a deal confirmation ticket is displayed to the trader.

In case the requester executes the trade with a competing market maker, the offer screen 

automatically closes with an according sound.

4.2 Pricing NDS

An NDS is priced by providing the spot rate and the swap points, potentially near and far points 

in case the request is a forward starting NDS.

In case a two-way request is made, the swap points have to be provided on the bid and on the 

offer side.

Once the price is sent to the requester, the buttons Cancel and Send are replaced by the buttons 

Interrupt and Requote. You can withdraw your quote by clicking Interrupt. By Requote, you can 

directly send a newly entered quote.

In case the user executes your offered price, a deal confirmation ticket is displayed to the trader.

Should the requester execute with another provider, the offer screen automatically closes with an 

according sound.
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4.3 Pricing Options

The price of an FX Option is the premium amount, which can be expressed in one of the 

two currencies of the underlying currency pair.

The market maker usually expresses the price of the option either in terms of the base currency 

per unit of the underlying currency (in pips), or in percent of the notional currency.

The quote is shown to the market taker in total premium amount with additional details of the price 

in pips of the premium currency and, in case that notional and premium currencies are the same, 

in % of this notional amount. If the taker requests an option price with separate delta hedge, he 

will also see the total notional of the spot hedge and as price indication also applied volatility in 

%.
User Guide 360T SEF

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5 SPECIAL EXECUTION MODES

As described previously, 2 additional special execution modes are possible. For simple FX 

products it is the multiple execution mode. For money market products it is the Up-to request 

mode usually combined with a multiple execution.

5.1 Allow Multiple Executions

The objective of the multiple execution mode is to split a large trade amount to several banks. 

The request will then be executed in a row with several of the pricing banks.

In case the option Allow multiple execution was selected on the Transaction tab of the product 

definition, once the first bid is executed, the competitive bidding screen remains open, while the 

remaining banks continue to price. Further executions are then possible, until the user clicks on 

Finish, which then stops the request to the remaining banks.

5.2 Rollover and Early Settlement of Trades

All dealblotters offer the possibility to rollover specific past trades.

NDF trades can be rolled over via the context menu in the dealblotter using the right mouse click 

or over the menu on the right of the dealblotter.

Rolling over an NDF automatically generates a new NDS based on the parameters of the rolled 

deal: near date of the NDS corresponds to the far date of the original deal; the same notional is 

assumed but can be modified. The request is then not only sent to the bank of the original rolled 

transaction, but simultaneously to other market makers as a new request for quote.
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6 SEF ORDER BOOK

The SEF Order Book allows the SEF enabled users to place limit orders that can be viewed by 

all other users registered as SEF Participants with 360T.

All users can view all orders placed in the SEF Order Book. Execution is only possible between 

entities that have a counterparty relationship with each other.

Orders displayed in black can be executed. Orders displayed in grey with obfuscated Company 

name are only indicative, as they originate from market participants without a relationship to the 

entity looking at the order book.

Orders for NDF, NDS and FX Options are supported in the SEF Order Book. In order to place an 

order on the SEF Order Book, a user must specify the relevant product, currencies and the 

notional amount to be traded. The minimum notional amount that can be specified is the relevant 

currency’s smallest monetary unit. The maximum notional amount is restricted to a fixed digit 

length determined by 360T based upon credit and market risk considerations. 360T may change 

these parameters at any time. Users can access these parameters through the Trading System.

A new order can be placed either by selecting New in the File menu, or by using the button

in the toolbar.

360T does not automatically match orders. The execution remains under the control of the market 

participants. If an order is displayed as tradable (in black), the user can execute it without placing 

an opposite order in the user interface but by marking it, opening the context menu over the right 

mouse click and then selecting Execute; or by opening it with a double-click and then clicking the 

Execute button.

The SEF Order Book and the Request for Streamed quotes (RFS) process interact in the following 

way:

If a RFS matches one or several orders in terms of: Action, Currency Couple, Effective Date and 

Maturity Date, Fixing Reference/Expiry and the notional is equal to the amount in the Limit Order 

and also the notional currency is the same as in the limit order then the best executable limit rate 

will be displayed in the competitive bidding window. In addition the best indicative limit rate will 

also be displayed in the RFS window if it is better than or equal to the best executable limit rate. 

A rate is considered indicative (non-executable), if no relationship to the company submitting the 

limit order exists.

Limit orders cannot be partially filled.

All orders placed in the SEF order book expire at the end of the trading day, i.e. at 5pm New York. 

A placed order can be canceled or amended by any user in the same company as the user who 

has entered the order.
User Guide 360T SEF

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7 CONTACTING 360T

Global Support

Phone: +49 69 900289-19

Fax: +49 69 900289-29

E-Mail: support@360t.com

EMEA Americas

Germany

360 Treasury Systems AG

Grueneburgweg 16-18

D-60322 Frankfurt am Main

Phone: +49 69 900289-0

Fax: +49 69 900289-29

USA

360 Trading Networks, Inc.

521 5th Avenue, 38th Floor

New York, NY 10175

Phone: +1 212 776 2900

Asia Pacific

Singapore

360T Asia Pacific Pte. Ltd.

One George Street

#07-04 One George

Singapore 049145

Phone: +65 6325 9970

Fax: +65 6536 0662