An LSEG Business

LCH | 10 Paternoster Square | London EC4M 7LS | T: +44 (0)20 7426 7000 | F: +44 (0)20 7426 7001 | lch.com

LCH Group Holdings Limited | LCH Limited | Banque Centrale de Compensation | LCH.Clearnet LLC

LCH Limited. Registered in England No. 25932 Registered Office: 10 Paternoster Square, London, EC4M 7LS

VIA CFTC PORTAL

14 December 2023 

Mr. Christopher Kirkpatrick

Commodity Futures Trading Commission

1155 21st Street NW

Three Lafayette Centre

Washington, DC 20581

LCH Limited Self-Certification: ForexClear fee changes 

Dear Mr. Kirkpatrick, 

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

Limited (“LCH”), a derivatives clearing organization registered with the CFTC, is submitting for selfcertification changes to the ForexClear fees that will be published on the LCH website. 

Part I: Explanation and Analysis

The ForexClear service charges fees to Clearing Members in relation to their activity in eligible

deliverable and non-deliverable FX products. These include fixed and variable components that are 

charged at the Clearing Member Corporate Group level. For more information, please see Fees | 

LCH Group. 

Part II: Description of Rule Changes

There are no changes to the LCH Rulebook, however LCH will make changes to the fee pages on 

its website. Please refer to Appendix I to see all the changes in blackline. The most substantive 

changes have been summarised below: 

Gold fee plan

- The Gold fee plan’s, for combined non-deliverable and deliverable FX, annual fee cap will

increase by £50k to £1.95m in 2024, and subsequently by another £50k to £2m in 2025.

- In addition, the Gold fee plan members can clear unlimited volume of outright Forward

transactions into the Forward service for £200k in 2024. This will be charged on a monthly

pro-rated basis and each member will be eligible for a 3-month fee holiday period. Specific

information on how the fee holiday period will commence and calculation of the first month’s

fee is provided in Appendix I.
Silver and Bronze fee plans

- The Silver fee plan, for non-deliverable FX, will increase by £375k to £900k. Exemption

from the non-deliverable options (NDO) clearing fees for Silver and Bronze fee plans has

been extended for an additional year until 31st December 2024.

Clients

- The non-deliverable FX only client fees remain the same, however they will now be

displayed in a separate table for ease of reading.

Deliverable service

- FX Options and FX Forwards fees for all fee plans will be displayed on the website (please

see Appendix I for more details). However, ForexClear is currently in the process of making

changes to the settlement process throughout 2024 and into Q1 2025 to further enhance

clearing of deliverable FX Options, Forwards, Swaps and Spot transactions. As a

result, anyone who wishes to join as an FX Option or Forward only member during that time

is invited to reach out to ForexClear via the Contact Us page to better understand the

implications of the enhancement.

Compression service

- The compression service will continue to be free for an additional year and until 1st January

2025 for all member and client fee plans.

Onboarding fee

- The one-off onboarding fee will continue to be $70k per each new ForexClear Clearing

Member, FCM ForexClear Clearing Member or ForexClear Dealer, but from the new year,

it will be capped at 5 charges per Corporate Group, with subsequent entities not incurring

any onboarding fees.

The new ForexClear fees will be published on the LCH website no earlier than 1st January 2024.

Part III: Core Principle Compliance

LCH reviewed the proposed changes against the requirements of the Core Principles and finds it 

will continue to comply with all the requirements and standards set forth therein. Specifically, these 

rule changes have potential relevance to Core Principle L under CFTC regulation §39.21

(Public information).

The changes described in this filing ensure that LCH meets the objectives of Core Principle L on 

Public Information, which requires DCOs to make publicly available clearing and other fees charged 

to Clearing Members. Publishing the changes to the ForexClear clearing fees in a timely manner 

will provide sufficient information to market participants to enable them to identify and evaluate 

accurately the costs associated with using its services. The above changes have also been 

discussed with the existing Clearing Members during a consultation period. 

Part IV: Public Information

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

LCH’s website at: https://www.lch.com/resources/rulebooks/proposed-rule-changes. 
Part V: Opposing Views

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

members of LCH or market participants. 

Certification

LCH 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 aleksandra.wojcik@lseg.com. 

Yours sincerely, 

Aleksandra Wojcik

Compliance Officer

LCH Limited
Appendix I

Website changes (ForexClear fees)

https://www.lch.com/services/forexclear/fees
Fees

ForexClear Clearing Members may be members of either or both of the ForexClear Deliverable Service and the ForexClear NonDeliverable Serviceselect which of the 3 ForexClear product offerings they wish to clear, from Non-deliverable Forwards (NDFs), 

Deliverable Options and Deliverable Forwards, and the corresponding fee plan. . ForexClear Clearing Members may choose from a 

variety ofthree fee tariffplans: Gold – cCombined Tariffplan, Bronze, Silver – unlimited volume and Bronze – fixed plus variable 

fees.and Zinc. Each tariff fee plan covers all house account trade registration activity for a ForexClear Clearing Member Groupand 

its affiliates, for the selected products.

For the purposes of all fee plans, a reference to a “ForexClear Clearing Member” includes an “FCM ForexClear Clearing Member”.

Member Fee Plans

ForexClear Gold TariffFee Plan – Combined Non-Deliverable and Deliverable FX Fee

Annual 

TariffFixed 

fee per 

annum*1

Options/ 

NDOs

Fee / 

million2**

FX spot /

Forward Hedges/ Swap 

Hedges and NDF

Fee / million

FX Forwards and 

FX Swaps

Settlement Fee** / 

million3***

Annual Fee 

Cap

GBP 

1,250,000

GBP 3 n/a 0.2 EUR or USD

2024 - GBP 

1,9500,000

2025 – GBP 

2,000,000
1. *The Annual Tariff includes unlimited clearing volumes for FX Swaps, FX Forwards and FX Spot (that (in each case) are not cleared for the

purpose of hedging FX Options) until 1st January 2024.In addition to the annual fee, Gold members can clear an unlimited amount of outright 

Forward transactions into the Forward service for £200,000 in 2024. Each ForexClear Clearing Member is eligible for a 3-month fee holiday 

commencing on the date that a fourth ForexClear Clearing Member has submitted an outright Forward transaction for clearing. Any Forward 

transactions cleared in 2023 will be considered to be trial transactions and, therefore, only eligible trades cleared by ForexClear Clearing 

Members from 1st January 2024 will count as submitting members for the purposes of fee activation. The fee holiday period expires 3 calendar 

months post of from the date of the first transaction (after the fourth member threshold has been reached), and all fee holiday periods will 

terminate on 31st December 2024r 31st, 2024. The £200,000 fixed fee will be charged on a monthly pro-rated basis, and the calculation of the 

first month's fees will use the number of remaining business days in that month, following the expiration of the fee holiday. 

2. **Options and Non- Deliverable Options (NDOs)DOs fees are applicable beyond the first $60bn cumulative notional cleared in each calendar 

year.

3. *** This settlement fee is Oonly applicable to FX Swaps and FX Forwards transactions that (in each case) are not cleared for the purpose of 

hedging FX Options (whereich hedging is undertaken either to reduce initial margin requirements or reduce settlement risk).
2024 Non-Deliverable FX Only Member Fees**

TariffFee Plan

Annual

TariffFixed Fee 

per annum

EMTA NDF

Fee / million

Non-EMTA NDF

Fee / million Annual Fee Cap

Client n/a US$ 2 US$ 1 n/a

Silver GBP 825900,000 n/a n/a n/a

Bronze US$ 350,000 US$ 2 US$ 1 US$1,250,000

**Silver and , BBronze and Client tariffsfees are exempted from Non-Deliverable OptionsDO clearing fees until 31st December 20243. 
2024 Deliverable FX Only Member Fees

Product FX Options FX Forwards

TariffFFee 

Plan

Annual

TariffFixe

d fee per 

annum

FX Options

Fee / 

million

FX spot /

Forward Hedges 

and Swap Hedges

Fee / million1

FX Forward

Settlement Fee / 

million**

Annual Fee Cap

Fixed fee per 

annum

FX Forwards

Fee / million

FX Forward

Settlement Fee / 

million3

Annual Fee 

Cap

Silver

GBP 

900885,0

00

n/a n/a n/a GBP 200,0007 n/a 0.2 EUR or USD n/a

ZincZinc2

GBP 

595,000*

GBP 

595,000

GBP 3 GBP 

3 n/an/a

0.2 EUR or USD0.2 

EUR or USD

GBP 

1,245,000GBP 

1,245,000

GBP 200,0008 n/a 0.2 EUR or USD n/a

Bronze

US$ 

400375,0

00

US$ 23.5 US$ 2 n/a 0.2 EUR or USD

n/aUS$1,500,000

GBP 200,0009 US$0.5 0.2 EUR or USD US$1,500,000

n/a

Note: New Clearing Members of the ForexClear FX Deliverable Options or Forwards Services will be eligible for a fee discount - please refer to ‘Fee 

Discounts’ 
1. Any FX Forward transaction that is deemed not to be hedge transaction and therefore considered to be an Outright FX Forward transaction 

and will be chargeable under the FX Forwards fee plan.

2. The Zinc fee plan expires on 31st December 2025 and is not available to any new participants. 

3. This settlement fee is only applicable to FX Swaps and FX Forwards transactions that (in each case) are not cleared for the purpose of 

hedging FX Options (where hedging is undertaken either to reduce initial margin requirements or reduce settlement risk).

4. This is the 2024 discounted rate, with the standard Silver Forwards fixed fee per annum being GBP 900,000. 

5. This is the 2024 discounted rate, with the standard Zinc Forwards fixed fee per annum being GBP 900,000. 

6. This is the 2024 discounted rate, with the standard Bronze Forwards fixed fee per annum being USD 375,000, capped at USD 1,500,000 with 

a variable fee of USD 0.5 per million. 

In order to make future enhancements to the clearing of deliverable FX Options, Forwards, Swaps and Spot transactions, ForexClear is making 

changes to the existing settlement process throughout 2024 and into Q1 2025. Any entity wishing to begin clearing deliverable FX Options or 

Forwards only during this time should use the Contact Us page to discuss the implications of our enhancements.

* The Zinc Annual Tariff includes unlimited clearing volumes for FX Swaps, FX Forwards and FX Spot that (in each case) are not cleared for the 

purpose of hedging FX Options) until 1st January 2024.

***Only applicable to FX Swaps and FX Forwards transactions that (in each case) are not cleared for the purpose of hedging FX Options (which 

hedging is undertaken either to reduce initial margin requirements or reduce settlement risk).
ForexClear Clearing Member – Changes to Fee Plans

Member Fees

Where a ForexClear Clearing Member wishes to move from a lower fee tariff to a higher fee plantariff, including to the combined Non-Deliverable and 

Deliverable Gold Tariffplan and, if the Member it gives notice to LCH by the 20thtwentieth day of the preceding month then , it will move to the newly 

selected fee tariff plan with effect from the firsteffective the 1st day of the following month. From that month the remaining monthly instalments of the 

calendar year will be payable at the newly elected fee tariffplan irrespective of fee amounts already invoiced under the ForexClear Clearing Member’s 

previous fee tariffplan. ForexClear Clearing Members may only move to a lower fee tariff at the start of the new calendar year. who wish to move to a 

lower fee plan should contact ForexClear to discuss. 
2024 Non-Deliverable FX Only Client Fees8

Fee Plan Fixed fee per 

annum

EMTA NDF

Fee / million

Non-EMTA NDF

Fee / million Annual Fee Cap

Client n/a US$ 2 US$ 1 n/a

8****Client fees are exempted from NDOFX clearing fees until 31st December 2024. 
Compression Fees (Member & Client Clearing)

• Gold, Silver, Bronze, Zinc and ForexClear Clearing Members and Clients tariffs will not be charged fees for using the ForexClear Compression 

sServices until 1st January 20254. 

• Thereafter, ForexClear Clearing Members and Clients will be charged US$1 per US$1 million of notional reduced using ForexClear 

Compression services. 

• A cap of US$500,000 per annum will apply per ForexClear Clearing Member and its affiliatesGroup for house account compression. of 

Member Group trades (i.e. proprietary trades).

• There is no cap on compression fees for clients.

Variable Fee Calculation

The Variable tariff fees are calculated on each trade as:

• [Notional amount of trade] * the per million (US$) notional fee from the relevant tier in the schedule above.

• ForexClear Client Clearing fees are calculated based on the total cleared notional in a calendar month for each independent Client Clearing 

portfolio.

Fee Discounts

ForexClear Deliverable Service

When first selecting the DeliverableOption or Forward Silver or Bronze tariff,fee plan, the first 3 months of fixed and variable fees will be waived.
Settlement Reduction Fees for the Deliverable Service

LCH will impose a fee as part of the automated settlement reduction process, leviedpayable againstby members who are in breach of relevant 

settlement limits at end of day on Settlement Date -2.

The fee will take the form of a “per unit of notional” charge against settlement amounts in excess of relevant currency settlement limits applied in 

respect of the excess of a ForexClear Clearing Mmember’s Settlement Position Amount over the Settlement Position Limit as per table below:

AUD CHF EUR GBP JPY

Bps on notional 0.26 0.23 0.2 0.22 0.2

EMIR Account Structures

For more information on EMIR account structure charges please click here
Fee Notes

All fees are billed monthly in arrears.

Fixed Member fees are pro-rated monthly where a ForexClear Clearing Member joins intra year.

A one-off on-boarding fee of $70,000 will be billed one month in arrears for each new ForexClear Clearing Member, FCM Clearing Member or 

ForexClear Dealer or Affiliate, which is a member of, or an Affiliated Firm of, a Membe the same corporater Group. This onboarding fee will be capped 

at 5 charges per Corporate Group, with subsequent entities not incurring any onboarding fees. 

Members clearing both non-deliverable and deliverable FX will be required to pay both non-deliverable and deliverable fees or the combined ‘Gold’ 

tariff. 

For a member to offer Client Clearing they must be part of a fee-paying MemberCorporate Group.

Client Clearing fees are billed to Clearing Members.

A "Client Clearing Portfolio" is a separate legally identified Client Account that exists at a specific Clearing Member. A Client Clearing Portfolio is 

unique to each Clearing Member.

A "Corporate Group" means a member and its Affiliates. For these purposes, an "Affiliate" includes any entity which is a subsidiary or has the same 

holding company as the member, as those terms are defined in s.1159 of the Companies Act 2006.

A "Member Group" means a ForexClear Clearing Member or an FCM Clearing Member, its direct and indirect subsidiaries and its direct and indirect 

holding companies and every direct and indirect subsidiary of each such holding company, from time to time. For the purposes of this definition: (i) 

‘subsidiary' means a company in which an entity holds more than 50% of the voting rights; and (ii) ‘holding company' means a company that holds 

more than 50% of the voting rights in another entity.

An "Affiliated Firm" in relation to a Member Group means a firm that satisfies both of the following tests:

• A ForexClear Clearing Member or a FCM Clearing Member (or any other member of its Member Group) holds 50% or more of the voting rights 

in the firm; and

• One or more ForexClear Clearing Members or FCM Clearing Members (or any other member of their Member Group) together hold more than 

50% of the voting rights in the firm.
"Voting rights" means the rights conferred on shareholders in respect of their shares or, in the case of a company not having a share capital, on 

members, to vote at general meetings of the company on all, or substantially all, matters.

Changes in an entity's corporate ownership may lead to changes in the tarifffee plan that applies to it.

Terms used herein are as defined in the rulebook of LCH, which you can access from the Quick Links below.