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

July 19, 2017 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 business development. The amended Rulebook will 

become effective on August 2, 2017.

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 September 27, 2016 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 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 September 27, 2016 is attached hereto as Exhibit C. No changes 

have been made to the User Guide for Market Takers or User Guide for Market Maker but for 

reference they are attached hereto as Exhibit D and Exhibit F respectively. 

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

Rule 402(a)

Revised Rule 402(a) to clarify the timeframe and type

of event where a Participant needs to provide

Required Notice to the Company. 

Clarification

Rule 526(e)

Amended Rule to allow parties amending or 

cancelling a trade without preapproval by the 

Company and requiring notification solely from the

Reporting Counterparty.

Core Principle 2

Rule 527(a)

Fixed a typo to read Rule 527 instead of Rule 528

Update

Rule 527(e)

Amended Rule to clarify that the Company limitation 

of liability does not extend to fraud, gross negligence

or willful misconduct. 

Clarification