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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

18 November 2022

Mr. Christopher Kirkpatrick

Commodity Futures Trading Commission

1155 21st Street NW

Three Lafayette Centre

Washington, DC 20581

LCH Limited Self-Certification: ForexClear NDO and Compression Service Fee Holiday 

Extension and Removal of Fee Discount for Non-Deliverable products

Dear Mr. Kirkpatrick,

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

(“LCH”), a derivatives clearing organization registered with the CFTC, is submitting for selfcertification website changes to accommodate an extension of the ForexClear fee holiday for NonDeliverable Options (NDOs) and the ForexClear compression service, as well as a removal of a 

monthly fee discount for the Clearing Member clearing the most non-deliverable FX volume by 

trade count.

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, as appropriate1. These include fixed and variable 

components and are charged at the Clearing Member Group level. LCH will extend a fee holiday 

for NDOs and the ForexClear compression service, as well as removal a monthly fee discount for 

the Clearing Member clearing the most non-deliverable FX volume by trade count.

Part II: Description of Rule Changes

There are no rulebook changes as part of this change, only the ForexClear website on fees will be 

updated as a result. The changes will include:

- Under the Non-deliverable FX only fees section, the exemption from NDOs clearing fees for 

Silver, Bronze and Client Tariffs will be extended until 31 December 2023 from 31 

December 2022.

1 Fees | LCH Group
• Under the Compression Fees (Member & Client Clearing) section, Gold, Silver, Bronze, 

Zinc and Client Tariffs will not be charged for using the ForexClear Compression Service 

until 1st January 2024, from 1

st January 2023. 

• Under the Fee Discounts section for ForexClear Non-Deliverable Service, the current 

monthly fee discount of £15,000 for the Clearing Member clearing the most non-deliverable 

FX volume by trade count will be removed all together. This had been introduced previously 

as a temporary discount. 

The changes to the ForexClear fees webpage are set out in Appendix I. The changes will be 

published on the webpage no earlier than December 8, 2022. 

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

(§39.21) on Public information, which requires DCOs to make available publicly each clearing and 

other fee charged to Clearing Members. Publishing the changes to 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.

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 Non-Deliverable Service. ForexClear Clearing Members may choose from a variety of fee tariffs: Gold –

Combined Tariff, Bronze, Silver and Zinc. Each tariff covers all house trade registration activity for a ForexClear 

Clearing Member Group.

ForexClear Gold Tariff – Combined Non-Deliverable and Deliverable FX Fee

Annual Tariff* Options/ NDOs

Fee / million**

FX spot /

Forward 

Hedges/ Swap 

Hedges and 

NDF

Fee / million

FX Forwards 

and FX Swaps

Settlement Fee** 

/ million***

Annual Fee Cap

GBP 1,250,000 GBP 2.50 n/a 0.2 EUR or USD GBP 1,850,000

*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.

**Options and NDOs fees are applicable beyond the first $60bn cumulative notional cleared in each calendar year.

*** 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).

Non-Deliverable FX Only Fees**

Tariff Annual

Tariff

EMTA NDF

Fee / million

Non-EMTA NDF

Fee / million

Client n/a US$ 2 US$ 1

Silver GBP 825,000 n/a n/a

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

*Non-deliverable bronze tariff is capped at US$1,250,000 per calendar year. 

**Silver, Bronze and Client tariffs are exempted from Non-Deliverable Options clearing fees until 31st December 

20232. 

 

Deliverable FX Only Fees

Tariff Annual

Tariff

FX Options

Fee / million

FX spot /

Forward 

Hedges and 

Swap 

Hedges

Fee / million

FX Forward

Settlement 

Fee / 

million**

Annual Fee 

Cap

Silver GBP 885,000 n/a n/a 0.2 EUR or 

USD

Zinc GBP 545,000* GBP 2.50 n/a 0.2 EUR or 

USD

GBP 

1,145,000

Bronze US$ 400,000 US$ 2 US$ 2 0.2 EUR or 

USD

Note: New Clearing Members of the ForexClear Deliverable Service will be eligible for a fee discount - please refer to 

‘Fee Discounts’ 
* 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 Option (which hedging is undertaken either to reduce initial margin requirements or reduce settlement 

risk).

Member Fees

Where a ForexClear Clearing Member wishes to move from a lower fee tariff to a higher fee tariff, including to the 

combined Non-Deliverable and Deliverable Gold Tariff, if the Member gives notice by the 20th of the preceding 

month, it will move to the newly elected fee tariff effective the 1st of the following month. From that month the 

remaining monthly instalments of the calendar year will be payable at the newly elected fee tariff irrespective of fee 

amounts already invoiced under the ForexClear Clearing Member’s previous fee tariff. ForexClear Clearing Members 

may only move to a lower fee tariff at the start of the new calendar year.

Compression Fees (Member & Client Clearing)

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

Service until 1st January 20243.

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

ForexClear Compression.

• A cap of US$500,000 per annum will apply per ForexClear Clearing Member Group for 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 Non-Deliverable Service

The ForexClear Clearing Member on the Silver or Bronze tariff that clears the most non-deliverable FX volume by 

trade count with respect to its house (i.e. proprietary) account, including any inter-affiliate trades, will receive a 

monthly fee discount of £15,000. The discount is applied to the Silver or Bronze ForexClear Clearing Member’s 

monthly fee bill in arrears and will end on 31st December 2022.

ForexClear Deliverable Service

When first selecting the Deliverable Silver or Bronze tariff, 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, levied against members who are in 

breach of relevant settlement limits at end of day on SD-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 member’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 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 Member 

Group.

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 Member 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 "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 tariff that applies to it.

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