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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.

24 November, 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 –

ICE Deposit Amendments 

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, amendments 

the rate of return paid by the Clearing House on Euro (“EUR”) and Pound Sterling 

(“GBP”) cash deposits and non-cash collateral.1 The amendments 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 amending its rate of return paid on EUR and GBP cash margin and 

Guaranty Fund deposits and on non-cash collateral applicable to all Clearing Members 

for house and customer accounts. ICE Clear Europe pays a rate of return on cash 

deposited by Clearing Members in respect of margin and Guaranty Fund requirements 

referred to as the ICE Deposit Rate (the “IDR”). The IDR is calculated daily and 

applied to cash balances held at the close of business on the previous business day in 

respect of US Dollar (“USD”), EUR and GBP deposits. The IDR is calculated as the 

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

Clearing Rules.
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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.

net income earned on cash deposits in the relevant currency (positive or negative) less 

a charge or spread. 

ICE Clear Europe is increasing the spread for EUR balances from 15 basis points to 20 

basis points and for GBP balances from 12 basis points to 20 basis points. The spread 

for USD will remain unchanged at 15 basis points. 

The Clearing House is also amending the charge applied to non-cash collateral margin 

deposits. For House and Affiliate Accounts, Segregated Customer Accounts and 

Standard Omnibus Indirect Customer Accounts the charge will increase from 8.33 basis 

points to 10 basis points. For Gross Omnibus Indirect Customer Accounts and 

Individually Segregated Operationally Co-mingled Accounts, the charge will increase 

from 10.33 basis points to 12 basis points. Finally, the charge for Individually 

Segregated Sponsored Accounts will increase from 13.33 points to 15 basis points. 

ICE Clear Europe has determined to implement these changes in light of current 

financial market conditions, including central bank rates for deposits in relevant 

currencies and repo rates available in the market for balances in relevant currencies. 

ICE Clear Europe believes the change would better align the relative costs and benefits 

of using cash in relevant currencies and non-cash collateral margin to cover margin and 

Guaranty Fund obligations with otherwise available market rates and facilitate the 

Clearing House’s ability to maintain adequate balances and non-cash collateral levels 

for liquidity management purposes. 

Compliance with the Act and CFTC Regulations

The amendments to the rate of return of EUR, GBP and non-cash collateral are 

potentially relevant to the following core principles: (B) Financial Resources and (F) 

Treatment of Funds and the applicable regulations of the Commission thereunder. 

• Financial Resources. As discussed above, the IDR changes are intended to 

better align the relative costs and benefits of using cash deposits in relevant 

currencies and thereby facilitate ICE Clear Europe’s liquidity management. 

The amendments are also intended to reflect costs of the Clearing House in 

holding non-cash collateral and more generally facilitate maintaining 

appropriate levels of non-cash collateral given current market conditions. As 

such, the amendments are consistent with the financial resources’

requirements of Core Principle B and Commission Rule 39.11.

• Treatment of Funds. As discussed above, ICE Clear Europe believes the IDR, 

as amended, will be reasonable and appropriate in light of market conditions, 

including available interest and repo rates for the relevant currencies. The 

modifications apply to all Clearing Members and other market participants 

who hold cash balances in EUR and GBP and/or non-cash collateral. ICE 

Clear Europe is not otherwise changing the manner in which EUR and GBP 

balances and/or non-cash collateral are held by the Clearing House. As a 

result, in ICE Clear Europe’s view, the amendments are consistent with the 

requirements of Core Principle F and Commission Rule 39.15. 
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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.

As set forth herein, the amendments consist of the changes to the IDR and non-cash 

collateral charges, as described in the Circular titled Notification of Changes to ICE 

Deposit Rate Spread for EUR and GBP and the basis points charged for Collateral 

Margin Deposits, a copy of which is attached hereto. 

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