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

November 12, 2020 www.360t.com

Submitted via CFTC 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 360T functionality development. The amended Rulebook will 

become effective on November 27

th, 2020. 

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 May 1st, 2020 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 7862 7509 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
Exhibit A

Summary: The 360T Rulebook has been amended in response to regulatory development. 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 May 1, 2020 is attached hereto 

as Exhibit C. Minor changes have been made to the User Guide for Market Takers and User Guide 

for Market Maker, they are attached hereto as Exhibit D and Exhibit E and a copy of the User 

Guides marked to show changes are attached hereto as Exhibit F and Exhibit G respectively. No 

changes have been made to the User Guide for 360TGTX but for reference it is attached as Exhibit 

H.

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

Updated Rule and page numbers as a new rule was added.

Update

Rule 527

Added Rule 527 (Post-Trade Name Give-Up) to clearly indicate that it is a 

violation of the Rulebook for a person to disclose the identity of a 

counterparty to a swap executed anonymously and intended to be cleared.

CFTC Rule 37.9(d)

User Guide Market Taker Cover Page 

Updated date

Update

User Guide Market Taker Section 7

Updated contact information for Asia Pacific

Update

User Guide Market Maker Cover Page 

Updated date

Update

User Guide Market Maker Section 7

Updated contact information for Asia Pacific

Update