July 13, 2023

VIA CFTC PORTAL

Mr Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

Re: Amendment to the LCH SA Fee Grid related to the Extension of Eligible Collateral to 

Include Additional Supranational and Agency Bonds under the Triparty Collateral 

Solution

Dear Mr. Kirkpatrick,

Pursuant to Commodity Futures Trading Commission (“CFTC”) Regulation § 40.6(a), LCH SA (“LCH SA”), 

a derivatives clearing organization (“DCO”) registered with the CFTC, certifies to the CFTC the amended

fee grid (the “Fee Grid”) related to the extension of eligible collateral to include additional supranational 

and agency bonds (“Additional Triparty Collateral”) under the triparty collateral solution for LCH SA’s

CDSClear service1(the “Proposed Rule Change”) expected to be effective on August 1st, 2023.However, 

in no event, it will either be implemented earlier than 10 business days after the proposed changes are 

filed with the CFTC.

The text of the Proposed Rule Change is attached hereto as Appendix A.

Part I: Explanation and Analysis

As part of the process to further enhance its triparty collateral service offering with Euroclear Bank and 

Euroclear France and to align the triparty collateral service offering across LSEG Group, LCH SA is 

extending the triparty offering to include the Additional Triparty Collateral and amending the Fee Grid.

Extension of Triparty Collateral Eligibility

Under the current list of eligible triparty collateral, LCH SA accepts European Union supranational debt

and Kreditanstalt für Wiederaufbau (“KfW”) agency debt. Under the Proposed Rule Change, LCH SA will

add the following supranational debt as eligible triparty collateral: European Financial Stability Facility; 

European Stability Mechanism; European Investment Bank; and Investment Bank for Reconstruction and 

Development. LCH SA also will add Landwirtschaftliche Rentenbank (“LR”) agency debt as eligible triparty 

1 The Triparty Collateral solution is already rule filed with the CFTC :

LCHSA_CDSClear_TripartyCollat_Full CFTC SelfCert_Formal_30 May 23.pdf
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collateral. The Additional Triparty Collateral is 3G pool ECB eligible and accepted at Euroclear Bank and 

Euroclear Settlement for Euronext-zone Securities (ESES).

Amendment to Fee Grid

LCH SA proposes to amend the Fee Grid following the extension of eligible collateral to include the 

Additional Triparty Collateral. This amendment will establish triparty fees for the Additional Triparty 

Collateral consistent with the spread between current eligible triparty collateral and bilateral collateral 

through Full Title of Transfer (“FTT”) deposit. In addition, LCH SA proposes to amend the triparty fee for 

European Union supranational debt and KfW agency debt to be consistent with the triparty fees for the 

Additional Triparty Collateral. Specifically, LCH SA proposes to make the following amendments to the 

Fee Grid:

• Amend the current triparty fee for European Union supranational debt from 9.5bps to 11.5bps;

• Amend the current triparty fee for KfW agency debt from 9.5bps to 11.5bps; and

• Establish a triparty fee of 11.5bps for the Additional Triparty Collateral.

Part II: Description of Rule Changes

No amendments to the LCH SA CDS Clearing Rule Book are required to effect these changes.

LCH SA proposes to extend the eligible collateral to include the Additional Triparty Collateral and amend 

the Fee Grid to align the triparty collateral service offering across LSEG. The Proposed Rule Change will 

provide a wider offering of eligible collateral through the triparty collateral solution and provide greater 

collateral optimization opportunities for LCH SA clearing members. Amendments to the Fee Grid will 

align the spread between the triparty collateral solution and the bilateral FTT deposit. Appendix A sets 

forth amendments to the Fee Grid.

Part III: Core Principle Compliance

LCH SA reviewed the Proposed Rule Change against the DCO Core Principles as set forth in the 

Commodity Exchange Act (“CEA”) and applicable CFTC regulations and concluded it is compliant

therewith. LCH SA notes the Proposed Rule Change will have a minimum impact on the following Core 

Principle and CFTC regulations including, but not limited to Regulation § 39.21.

• DCO Core Principle L – Public Information. LCH SA has determined that the Proposed Rule 

Change is consistent with DCO Core Principle L and CFTC Regulation § 39.21 requiring each 

clearing and other fee charged to clearing members be made available publicly. The amended 

Fee Grid will be made publicly available on the LCH SA website once the Proposed Rule Change 

becomes effective and LCH SA will ensure that sufficient information is provided to market 

participants so that they can identify and evaluate accurately the fees associated with using the 

relevant clearing services. As a result of this review, LCH SA believes the Proposed Rule Change

is consistent with DCO Core Principle L and CFTC Regulation § 39.21.
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Part IV: Public Information

LCH SA has submitted a notice of pending certifications to the CFTC and posted a copy of the submission 

on LCH SA’s website at: https://www.lch.com/resources/rulebooks/proposed-rule-changes.

Part V: Opposing Views

There were no substantive opposing views expressed to LCH SA by governing board or committee 

members, or clearing members of LCH SA that were not incorporated into the Proposed Rule Change.

Certification

LCH SA hereby certifies to the CFTC, pursuant to the procedures set forth in CFTC Regulation § 40.6, that 

the Proposed Rule Change complies with the CEA, as amended, and the regulations promulgated 

thereunder.

If you require any additional information or have any questions regarding this submission, please 

contact the undersigned.

Best regards,

Carole Uzan

Chief Compliance Officer

+33 1 86 47 64 82

carole.uzan@lseg.com

Attachment: Appendix A: Securities Collateral Fee/Spread (bps)
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APPENDIX A

LCH SA CDSClear Fee Grid effective as of August 1, 2023

Securities Full Title Transfer Pledge Triparty CDSClear 

Clients

Government 

Securities

Australia 13 N/A N/A 10

Austria 11 15 9.5 10

Belgium 11 15 9.5 10

Canada 13 N/A N/A 10

Denmark 13 N/A N/A 10

Finland 11 15 9.5 10

France 11 15 9.5 10

Germany 11 15 9.5 10

Italy 11 15 9.5 10

Japan 13 N/A N/A 10

Netherlands 11 15 9.5 10

Norway 13 N/A N/A 10

Portugal 11 N/A 9.5 10

Spain 11 15 9.5 10

Sweden 13 N/A N/A 10

Switzerland 13 N/A N/A 10

UK 11 15 N/A 10

USA 11 15 N/A 10

Supranationals

European Financial 

Stability Facility 13 15 N/A 11.5 10

European Stability 

Mechanism 13 15 N/A 11.5 10

European Investment 

Bank 13 15 N/A 11.5 10

European Union 13 15 9.5 11.5 10

Investment Bank for 

Reconstruction and 

Development

13 15 N/A 11.5 10

Agencies

Rentenbank 13 15 N/A 11.5 10

Kreditanstalt für 

Wiederaufbau 13 15 9.5 11.5 10

Equities All (as listed in Haircut 

Schedule) 13 N/A N/A N/A