www.theice.com

Intercontinental Exchange

353 North Clark, Suite 3100

Chicago, IL 60654

Olivia Bazor

Staff Attorney March 31, 2023

Re: Changes to ICC Rules to Provide 

for Clearance of Additional CDS 

Contracts Pursuant to Section 5c(c)(1) 

of the Commodity Exchange Act and 

Commission Regulation 40.6

VIA ELECTRONIC PORTAL

Mr. Christopher Kirkpatrick

Secretary

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, D.C. 20581

Dear Mr. Kirkpatrick:

ICE Clear Credit LLC (“ICC”) hereby submits, pursuant to Section 5c(c)(1) of the Commodity 

Exchange Act and Commodity Futures Trading Commission (“Commission”) Regulation 40.6, a 

self-certification of changes to the ICC Rulebook (the “Rules”) to provide for the clearance of an 

additional Standard Emerging Market Sovereign CDS Contracts and Standard Western European 

Sovereign Single Name CDS contracts (collectively, the “Sovereign Contracts”). ICC is registered 

with the Commission as a derivatives clearing organization (“DCO”). ICC intends to make the 

amended Rules effective no sooner than the tenth business day following the filing of this 

submission with the Commission at its Washington, D.C. headquarters and with its Chicago 

regional office.

This submission includes the amended Rules. A description of the principal changes contained in 

the amended Rules follows. Certification of the amended Rules pursuant to Section 5c(c)(1) of the 

Act and Commission Regulation 40.6 is also provided below.

The purpose of the proposed rule change is to adopt rules that will provide the basis for ICC to clear 

additional credit default swap contracts. ICC believes the addition of these contracts will benefit the 

market for credit default swaps by providing market participants the benefits of clearing, including 

reduction in counterparty risk and safeguarding of margin assets pursuant to clearing house rules. 

Clearing of the additional Sovereign Contracts will not require any changes to ICC’s risk 

management framework.

ICC proposes amending Subchapter 26D and Subchapter 26I of its Rules to provide for the 

clearance of additional Sovereign Contracts, specifically the Socialist Republic of Vietnam, 

Romania, and Kingdom of Sweden. These additional Sovereign Contracts have terms consistent 

with the other Sovereign Contracts approved for clearing at ICC and governed by Subchapter 26D 

and 26I of the Rules. Minor revisions to Subchapter 26D (Standard Emerging Market Sovereign 

(“SES”) Single Name) and 26I (Standard Western European Sovereign (“SWES”) Single Name) are 
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made to provide for clearing the additional Sovereign Contracts. Specifically, in Rule 26D-102 

(Definitions), “Eligible SES Reference Entities” is modified to include the Socialist Republic of 

Vietnam and Romania in the list of specific Eligible SES Reference Entities to be cleared by ICC. 

Also, specifically, in Rule 26I-102 (Definitions), “Eligible SWES Reference Entities” is modified to 

include the Kingdom of Sweden in the list of specific Eligible SWES Reference Entities to be 

cleared by ICC.

Core Principle Review: 

ICC reviewed the DCO core principles (“Core Principles”) as set forth in the Commodity Exchange 

Act. During this review, ICC identified the following Core Principles as being impacted: 

Participant and Product Eligibility: ICC has set appropriate standards in ICC’s policies and 

procedures for determining the eligibility of contracts. The additional Sovereign Contracts fulfill 

ICC’s standards regarding product eligibility. 

Risk Management: ICC will apply its established margin and pricing methodology to the additional 

Sovereign Contracts. 

Settlement Procedures: The additional Sovereign Contracts are subject to ICC’s current physical 

settlement rules under Chapter 22: CDS Physical Settlement. 

Amended Rules: 

The proposed change consists of revisions to Chapter 26 of the ICC Rules to provide for the 

clearance of the additional Sovereign Contracts. 

Annexed as an Exhibit hereto is the following: 

A. Proposed amendments to the ICC Rules 

Certifications: 

ICC hereby certifies that the amended Rules comply with the Act and the regulations thereunder. 

There were no substantive opposing views to the rules.

ICC certifies that, concurrent with this filing, a copy of the submission was posted on ICC’s 

website, which may be accessed at: https://www.theice.com/clear-credit/regulation.

ICC would be pleased to respond to any questions the Commission or the staff may have regarding 

this submission. Please direct any questions or requests for information to the attention of the 

undersigned at (904) 855-5580. 

Sincerely,

Olivia Bazor

Staff Attorney