1

Registered name: ICE Clear Europe Limited, (Registered in England, No. 06219884)

Registered office: Milton Gate, 60 Chiswell Street, London EC1Y 4SA, United Kingdom

ICE Clear Europe Ltd is a recognised clearing house under the Financial Services and Markets Act 2000 and is supervised by the 

Bank of England.

December 6, 2023

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: ICE Clear Europe Self-Certification Pursuant to Commission Rule Rule 40.6 –

Risk Identification Framework

Dear Mr. Kirkpatrick:

ICE Clear Europe Limited (“ICE Clear Europe” or the “Clearing House”), a registered 

derivatives clearing organization under the Commodity Exchange Act, as amended (the 

“Act”), hereby submits to the Commodity Futures Trading Commission (the 

“Commission”), pursuant to Commission Rule 40.6 for self-certification, this rule 

change retiring its Risk Identification Framework (the “Framework”).1 The change will 

become effective on the first business day following the tenth business day after 

submission, or such later date as ICE Clear Europe may determine. 

Concise Explanation and Analysis

ICE Clear Europe is retiring its Risk Identification Framework, which the Clearing 

House believes is outdated and has been superseded by other of the Clearing House’s 

rules, policies, procedures and risk management practices. The existing Risk 

Identification Framework outlines certain considerations and practices for the 

Clearing House Board in classifying, exploring, identifying and monitoring material 

risks faced by the Clearing House. ICE Clear Europe believes that these matters are 

more fully covered in other Clearing House documentation and practices. The 

1 Capitalized terms used but not defined herein have the meanings specified in the ICE Clear Europe 

Clearing Rules.
2

Registered name: ICE Clear Europe Limited, (Registered in England, No. 06219884)

Registered office: Milton Gate, 60 Chiswell Street, London EC1Y 4SA, United Kingdom

ICE Clear Europe Ltd is a recognised clearing house under the Financial Services and Markets Act 2000 and is supervised by the 

Bank of England.

Clearing House does not anticipate that the retirement of the Risk Identification 

Framework will change its policies or practices as it relates to its management of risk.

Compliance with the Act and CFTC Regulations

The retirement of the Framework is potentially relevant to the following core principle: 

(D) Risk Management and the applicable regulations of the Commission thereunder. 

• Risk Management. As stated above, ICE Clear Europe is retiring the 

Framework as it is no longer necessary in light of other existing rules, polices, 

procedures and practices relating to risk management. In particular, the 

retirement of the Framework is not expected to result in changes to Clearing 

House risk management policies or practices. The amendment is thus 

consistent with the requirements of Core Principle D and Commission Rule 

39.13.

As set forth herein, the amendment consists of the retiring of the Risk Identification 

Framework. ICE Clear Europe has requested confidential treatment with respect to the 

Risk Identification Framework, which has been submitted concurrently with this selfcertification submission.

ICE Clear Europe hereby certifies that the amendments comply with the Act and the 

Commission’s regulations thereunder.

ICE Clear Europe received no substantive opposing views in relation to the 

amendments.

ICE Clear Europe has posted a notice of pending certification and a copy of this 

submission on its website concurrent with the filing of this submission. 

If you or your staff should have any questions or comments or require further 

information regarding this submission, please do not hesitate to contact the undersigned 

at George.milton@theice.com or +44 20 7429 4564. 

Very truly yours,

George Milton

Head of Regulation & Compliance