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(a) Parties involved in the solicitation or negotiation of a Block Trade 

and parties that are privy to nonpublic information regarding a 

consummated Block Trade may not disclose such information to any 

other party prior to the public report of the Block Trade by the 

Exchange and may not trade in the same product or closely-related 

product for the purpose of taking advantage of such information. 

(b) A buyer or seller to a potential Block Trade may engage in prehedging or anticipatory hedging of the position that it believes in 

good faith will result from the consummation of the Block Trade. In 

addition, buyers or sellers to a Block Trade are permitted to initiate 

trades to hedge or offset the risk associated with the Block Trade 

following the consummation of the Block Trade, including during 

the period preceding the public report of the Block Trade by the 

Exchange. However, an Authorized Broker that accepts or facilitates 

the execution of a Block Trade is subject to the prehedging/anticipatory hedging prohibition, which also applies to any 

account that is owned or controlled by, or in which an ownership 

interest is held by, including a proprietary account of the employer 

of, such Authorized Broker. 

4.7 Exchange for Related Position (EFRP) 

4.7.1 Categories of EFRP

Participants and/or Customers, as applicable, may enter into the following 

type of Exchange for Related Position transaction (“EFRP”) in accordance 

with the provisions of this Rule: 

(a) an Exchange for Physical transaction (“EFP”), which is a privately 

negotiated and simultaneous exchange of a futures position in a 

Nodal Contract for a corresponding cash position. EFPs on Nodal 

Exchange may be executed for Nodal Contracts based on natural gas 

and environmental products only and their corresponding cash 

positions; 

(a)(b) An Exchange for Swap (“EFS”) and an Exchange for Risk (“EFR”) 

are the same type of transaction. An EFS/EFR is an off-exchange 

bilaterally negotiated transaction involving the simultaneous 

exchange of an Exchange futures position for a corresponding 

related off-exchange swap or other off-exchange derivative in the 

same or related product. EFS/EFRs on Nodal Exchange may be 

executed for Nodal Contracts based on power, natural gas and 

environmental products and their corresponding cash positions. 
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EFPs on Nodal Exchange may be executed for Nodal Contracts based on 

natural gas and environmental products only and their corresponding cash 

positions. 

4.7.2 EFRP Requirements

(a) An EFRP shall consist of two discrete but related simultaneous 

transactions in which one party must be the buyer of (or the holder 

of the long market exposure associated with) the related position and 

seller of the corresponding Nodal Contract, and the other party must 

be the seller of (or the holder of the short market exposure associated 

with) the related position and the buyer of the corresponding Nodal 

Contract. The related position must involve the Commodity 

underlying the Nodal Contract (or any derivative, by-product or 

related product that has a reasonable degree of price correlation to 

the Nodal Contract) in a quantity that is approximately equivalent to 

the quantity covered by the Nodal Contract. 

(b) The accounts involved in the execution of an EFRP must be: 

i. independently controlled with different beneficial owners; 

or 

ii. independently controlled accounts of separate legal entities 

with the same beneficial owners, provided that the account 

controllers operate separate business units; or 

iii. independently controlled accounts within the same legal 

entity, provided that the account controllers operate in 

separate business units; or 

iv. commonly controlled accounts of separate legal entities, 

provided that the separate legal entities have different 

beneficial owners. 

(c) The parties to an EFRP shall maintain all documents relevant to the 

Nodal Contract and the related position, including all documents 

customarily generated in accordance with the relevant market 

practices, including, as applicable, copies of the documents 

evidencing title to, or the contract or contracts to buy or sell, the 

underlying Commodity (or the derivative, by-product or related 

product) involved in such EFRP. Any such documents and 

information shall be furnished to the Exchange upon request. 

(d) The price of the Nodal Contract exchanged in an EFRP must be 

mutually agreed, commercially reasonable and consistent with the 

price increments set forth in the applicable Contract Specification.