SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): ___________________________ 

Organization: ______________________________________________________________________ 

Filing as a: DCM SEF DCO SDR Please note - only ONE choice allowed. 

Filing Date (mm/dd/yy): ___________ Filing Description:

SPECIFY FILING TYPE Please note only ONE choice allowed per Submission. 

Organization Rules and Rule Amendments

Certification § 40.6(a)

Approval § 40.5(a)

Notification § 40.6(d)

Advance Notice of SIDCO Rule Change § 40.10(a)

SIDCO Emergency Rule Change § 40.10(h)

 Rule Numbers: ____________________________________________________________________ 

New Product Please note only ONE product per Submission.

Certification § 40.2(a) 

Certification Security Futures § 41.23(a)

Certification Swap Class § 40.2(d)

Approval § 40.3(a)

Approval Security Futures § 41.23(b) 

Novel Derivative Product Notification § 40.12(a)

Swap Submission § 39.5

 Official Product Name: _____________________________________________________________ 

Product Terms and Conditions (product related Rules and Rule Amendments)

Certification § 40.6(a) 

Certification Made Available to Trade Determination § 40.6(a)

Certification Security Futures § 41.24(a)

Delisting (No Open Interest) § 40.6(a) 

Approval § 40.5(a)

Approval Made Available to Trade Determination § 40.5(a)

Approval Security Futures § 41.24(b)

Approval Amendments to enumerated agricultural products § 40.4(a), § 40.5(a)

“Non-Material Agricultural Rule Change” § 40.4(b)(5)

Notification § 40.6(d)

 Official Name(s) of Product(s) Affected: ________________________________________________ 

Rule Numbers: ______________________________________________________________________ 
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

December 24, 2014

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. The amended Rulebook will 

become effective on January 9, 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 April 3, 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 April 3, 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 

Rule 310(d)

Added Rule 310(d) to reflect that each Clearing Firm 

that guarantees swaps intended to be cleared is subject 

to 360T’s jurisdiction. 

Commission Regulation 37.700 

Rule 701(a)

1. Revised to remove language related to a Person

subject to the Company’s jurisdiction being

subject to the Company’s jurisdiction

2. Revised to include language that Customers and

Clearing Firms to be subject to Chapter 7

1. Clarification

2. Commission Regulation 37.206 and

Commission Guidance

Rule 701(g)(5)

Added Rule 701(g)(5) to include language explaining 

how 360T may sanction market participants and 

sponsoring participants. 

Commission Regulation 37.206

Rule 714

Revised language to include Clearing Firms as 

entities that may be sanctioned. 

Commission Regulation 37.206 and 

Commission Guidance