Refinitiv US SEF LLC

28 Liberty Street – 57th Floor

New York, NY 10008

www.refinitiv.com

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December 12, 2022

SUBMITTED 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: Submission 22-03: Refinitiv US SEF LLC – Fee Schedule 

Dear Mr. Kirkpatrick,

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

SEF LLC (“RSEF”), a swap execution facility registered with the CFTC, is submitting for selfcertification amendments to its fee schedule in order to extend its Request for Stream Incentive

(“RFS Fee Waiver Incentive”) through the first half of 2023 and clarify the separate fees for 

Request for Quote (“RFQ”) and Request for Stream (“RFS”) (collectively, “Proposed Rule 

Change”). 

The Proposed Rule Change will not become effective before December 27, 2022. The text of the 

Proposed Rule Change is attached hereto as Exhibit A.

Part I: Explanation and Analysis

RSEF offers an RFS platform, through which RSEF Participants can request a continuous stream 

of quotes from other RSEF Participants. RSEF has decided to extend its RFS Fee Waiver 

Incentive by six months to encourage participants on RSEF to use the Request for Stream 

execution mechanism for trading their Non-Deliverable Forward swaps.

Part II: Description of Rule Changes

The previous RFS Fee Waiver Incentive was set to expire December 31, 2022. RSEF is proposing 

to extend the RFS Fee Waiver Incentive by six months through June 30, 2023. Additionally, RSEF 

has reformatted the Fee Schedule to clarify the difference between pricing for RFQ and RFS. 

There is no actual change to the RFQ or RFS pricing.

Part III: Core Principle Compliance

RSEF reviewed the Proposed Rule Change against the requirements of the Core Principles and 

finds it will continue to comply with all requirements and standards set forth therein. Specifically,

this rule change has potential relevance to Core Principle 2 (Compliance with Rules).

The changes described in this filing ensure RSEF meets the objectives of Core Principle 2, 

including that, in accordance with CFTC Regulation §37.200, RSEF has established rules 

governing the operation of RSEF, specifically any applicable fees. RSEF considered its rule 

compliance requirements and believes including the Proposed Rule Change in its rules maintains 

compliance with Core Principle 2.
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Part IV: Public Information

RSEF has posted a notice of pending certification with the CFTC and a copy of the submission 

on RSEF’s website at: https://www.refinitiv.com/en/products/sef-swap-execution-facility.

Part V: Opposing Views

There were no opposing views expressed to RSEF by governing board or committee members,

or market participants.

Certification

RSEF hereby certifies to the CFTC, pursuant to the procedures set forth in CFTC Regulation 

§40.6, that the attached submission complies with the Commodity Exchange Act, as amended, 

and the regulations promulgated thereunder.

Should you have any questions, please contact me at Michelle.Weiler@lseg.com

Sincerely, 

Michelle Weiler

Chief Compliance Officer
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EXHIBIT A

Amended Fee Schedule