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

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

March 13, 2015

Submitted via Electronic Mail (submissions@cftc.gov) and Portal

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 Amendments

Ladies and Gentlemen:

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. The Rulebook 

has been amended in response to Commission staff guidance as well as 360T business 

development. The amended Rulebook will become effective on March 27, 2015.

A concise explanation and analysis of the amendments to the Rulebook 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 December 24, 2014 is attached hereto as Exhibit C.

360T hereby certifies that: (i) the amended Rulebook complies 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 to the Rulebook.
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

Attachments

2
Exhibit A

Summary: The 360T Rulebook has been amended in response to published 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 December 24, 2014 is attached 

hereto as Exhibit C.

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

Amendment Explanation

Cover Page

Revised effective date Update

Table of Contents

Revised page numbers. Update

Chapter 1

1. Further defined certain defined terms: 

a. Amended Rule reference of “No-Bust 

Range”

b. Introduced definition of “Prime Broker”

and “Prime Broker Transaction”

2. Conformed definitions to their appearance in 

the Rulebook

1. Clarification

2. Clarification

Rule 401(a)(8)

Amended Rule 401(a)(8) to state that records are to 

be made available to the CFTC upon request.

CFTC Regulation 37.404

Rule 504

Amended to restrict Persons subject to 360T’s 

jurisdiction from engaging in front running, 

fraudulent trading, trading ahead of customers, 

trading against customer orders, and improper cross 

trading.

CFTC Regulation 37.203(a)

Rule 524

Revised Rule to require that Required Transactions 

must be executed using the order book or request for 

quote functionality.

CFTC Regulation 37.9

Rule 526(d)

Amended paragraph reference to No-Bust Range.

Clarification
Rule 526(e)

Added new Rule 526(e) to allow the cancellation of 

Prime Broker Transactions under the circumstances 

described in the Rule. A Prime Broker as a 

counterparty to a Prime Broker Transaction needs to 

have the ability to cancel the Prime Broker 

Transaction if the Participant that trades in the Prime 

Broker’s name exceeds the scope of authority granted 

to it by the Prime Broker.

Core Principle 2

Rule 526(i)

Added new Rule 526(i) to ensure that trade price 

adjustments or trade cancellations will be transparent 

to the market and subject to standard that are clear, 

fair and publicly available.

CFTC Regulation 37.203(e)

Rule 526(g)-(j)

Adjusted numbering. 

Clarification

Rule 712

Amended Rule to require that all Disciplinary 

Proceedings are fair and conducted before members 

of the Disciplinary Panel.

CFTC Regulation 37.206(c)(1)

Rule 712(g)

Added new Rule 712(g) to ensure that if the 

respondent has requested a hearing, a copy of the 

hearing will be made and become part of the record. 

The record will not be required to be transcribed 

unless the circumstances as detailed in Rule 712(g) 

are met.

CFTC Regulation 37.206(c)(2)

Rule 903(d)

Amended Rule 903(d) that prohibits 360T from using

for business or marketing purposes any proprietary 

data or personal information it collects for the 

purpose of fulfilling its regulatory obligations, unless 

the person from whom it collects or receives such data 

or information consents in writing to 360T’s use of 

such data or information in such manner.

CFTC Regulation 37.7

Rule 904

Adjusted numbering.

Clarification

Rule 904(c) Core Principle 5

2
Added Rule 904(c) to allow 360T to provide nonpublic information to the CFTC.

Rule 912

Adjusted numbering

Clarification

Rule 912(b)(3)

Added Rule 912(b)(3) to allow 360T to order the 

fixing of a settlement price in the event of an 

emergency.

Core Principle 8

3