BGC Derivative Markets, L.P

Rule Implementation Submission 2020-02

November 24, 2020

1. The texts of the amended Rules are appended as Attachment A. Any additions are 

underlined and any deletions are struck through.

2. The date of intended implementation for these rules is ten business days following the 

filing of this submission.

3. Attached, please find a certification that: (1) these rules comply with the Commodity 

Exchange Act (“Act”), and the Commission’s regulations thereunder; and (2) concurrent 

with this submission, BGCDMLP posted on its website: (i) a notice of pending 

certification of the rule amendments with the Commission; and (ii) a copy of this 

submission.

4. A concise explanation and analysis of the operation, purpose, and effect of each of the 

amended rules appears below.

5. There were no opposing views expressed regarding these amended rules.

6. Confidential treatment is not requested.

CONCISE EXPLANATION AND ANALYSIS OF THE OPERATION, PURPOSE, AND 

EFFECT OF THE RULE AMENDMENT AND ITS COMPLIANCE WITH APPLICABLE 

PROVISIONS OF THE ACT, INCLUDING CORE PRINCIPLES AND THE 

COMMISSION’S REGULATIONS THEREUNDER

Pursuant to Commission Rule 40.6(a)(7)(vi), the following is a concise explanation and analysis 

of the operation, purpose, and effect of the amended rules. The attached amendments are 

cumulative and in response to suggestions and guidance from the staff during the course of the 

staff review of the BGCDMLP application for registration as a Swap Execution Facility. These 

amendments are either:

(1) technical corrections to align the rules more closely with the language of Commission 

Rules; and/or

(2) amendments made in response to guidance of Commission staff.

The following chart identifies the changed rules and notes the effect of the change and an 

explanation of the operation, purpose, and effect of the change.
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CONCISE EXPLANATION AND ANALYSIS OF THE OPERATION, PURPOSE, AND 

EFFECT OF THE RULE AMENDMENT AND ITS COMPLIANCE WITH APPLICABLE 

PROVISIONS OF THE ACT

Rule Rule Title Effect

506 Allocation and Priority of Orders; 

No Withholding of Orders

Amend text to update relief reference to 

CFTC Letter No. 20-36 and date of 

expiration of relief.

510(g) Block trades Amend text to update relief reference to 

CFTC Letter No. 20-35 and date of 

expiration of relief.

604 Confirmation of Voice Transactions 

and Objections

Clarify rule with respect to Rule 517. PostTrade Anonymity.

704 Package Transactions Clarify rule with respect to Rule 517. PostTrade Anonymity.
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CERTIFICATIONS PURSUANT TO SECTION 5c OF THE COMMODITY EXCHANGE 

ACT, 7 U.S.C. §7A-2 AND COMMODITY FUTURES TRADING COMMISSION RULE 40.6, 

17 C.F.R. §40.6

I hereby certify that:

(1) the amended Rules above comply with the Commodity Exchange Act, and the 

Commodity Futures Trading Commission’s regulations thereunder; and

(2) concurrent with this submission, BGC Derivative Markets, L.P. posted on its website:

(a) a notice of pending certification of the above Rules with the Commission; and (b) 

a copy of this submission

By: Michael C. Sulfaro

Title: Chief Compliance Officer 

Date: November 24, 2020
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BGC Derivative Markets, L.P. Rules

PART 5. TRADING.

506. Allocation and Priority of Orders; No Withholding of Orders

Each Participant shall ensure that Orders are allocated to the appropriate accounts. Orders subject to 

allocation may be submitted through the Facility and allocated by a Participant in a manner permitted 

under Applicable Law. Notwithstanding anything to the contrary in Rule 506, the Commission 

provides relief in CFTC Letter No. 20-36 from the audit trail requirements in Commission regulation 

37.205 until November 15, 2021, or such earlier date of a Commission action, including without 

limitation a rulemaking or order, providing a permanent solution for SEF audit trail obligations 

related to post-execution allocation information.

510. Block trades

(g) Notwithstanding anything to the contrary in this Rule 510, until November 15, 

2020December 30, 2022, or such later time as the relief in CFTC Letter No. 20-3517-

60 shall be extended, the Facility may facilitate the execution of Block Trades within 

the scope of this Rule 510 that are intended to be cleared by enabling the applicable 

Clearing Participants to complete the pre-execution credit check required under 

Commission Rule 1.73 pursuant to the procedures of Rules 501(d) and Rule 502(b)(ii) 

at the time a Block Trade is identified to the Facility. Execution of the Block Trade 

shall not occur until completion of the pre-execution credit check. Block Trades which 

are rejected on the basis of credit at the time that they are identified to the Facility shall 

be void ab initio.

PART 6. TRADING VIA ELECTRONIC ORDER BOOK.

604. Confirmations and Objections.

The confirmation of all terms of the transaction shall take place at the same time as execution; 

provided however, specific customer identifiers need not be included for accounts included in 

bunched orders meeting the requirements of Rule 506(d) and Commission Rule 1.35(b)(5) or in 

accordance with Rule 517..
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PART 7. TRADING VIA VOICE FUNCTIONALITY.

704. Confirmation of Voice Transactions and Objections.

The confirmation of all terms of the transaction shall take place at the same time as execution; 

provided however, specific customer identifiers need not be included for accounts included in 

bunched orders meeting the requirements of Rule 506(d) and Commission Rule 1.35(b)(5) or in 

accordance with Rule 517..

.