SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 20-455

Organization: NEX SEF LIMITED ("NEX SEF")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): October 16, 2020 Filing Description: Modifications to the NEX 

SEF African & Middle East NDFs Market Maker Program

SPECIFY FILING TYPE 

Please note only ONE choice allowed per Submission.

Organization Rules and Rule Amendments

Certification § 40.6(a)

Approval § 40.5(a)

Notification § 40.6(d)

Advance Notice of SIDCO Rule Change § 40.10(a)

SIDCO Emergency Rule Change § 40.10(h)

Rule Numbers: N/A

New Product Please note only ONE product per Submission.

Certification § 40.2(a) 

Certification Security Futures § 41.23(a)

Certification Swap Class § 40.2(d)

Approval § 40.3(a)

Approval Security Futures § 41.23(b)

Novel Derivative Product Notification § 40.12(a)

Swap Submission § 39.5

Official Product Name: 

Product Terms and Conditions (product related Rules and Rule Amendments)

Certification § 40.6(a) 

Certification Made Available to Trade Determination § 40.6(a)

Certification Security Futures § 41.24(a)

Delisting (No Open Interest) § 40.6(a) 

Approval § 40.5(a)

Approval Made Available to Trade Determination § 40.5(a)

Approval Security Futures § 41.24(c)

Approval Amendments to enumerated agricultural products § 40.4(a), § 40.5(a)

“Non-Material Agricultural Rule Change” § 40.4(b)(5)

Notification § 40.6(d)

Official Name(s) of Product(s) Affected: 

Rule Numbers: 
300 Vesey Street New York, NY 10282 T 212 521 4609 nirup.ramalingam@cmegroup.com cmegroup.com

1

Nirup Ramalingam

Chief Operating Officer

NEX SEF LIMITED

October 16, 2020

VIA ELECTRONIC PORTAL

Division of Market Oversight

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Modifications to the NEX SEF African & Middle East NDFs Market Maker Program

NEX SEF Submission No. 20-455

To Whom It May Concern:

Pursuant to Section 5c(c) of the Commodity Exchange Act (“CEA”) and Section 40.6(a) of the regulations of the 

Commodity Futures Trading Commission (“CFTC” or “Commission”), NEX SEF Limited (“NEX SEF”) hereby notifies 

the Commission of modifications to NEX SEF’s African & Middle East NDFs Market Maker Program (“Program”). The 

modifications to the Program will be effective on November 1, 2020.

The modified Program is set forth in Appendix A below, with additions underlined and deletions overstruck. A clean 

version of the modified Program is set forth in Appendix B below. A request for confidential treatment of the Program

is being simultaneously submitted to the Commission and a copy of that request for confidential treatment is included 

with this submission.

NEX SEF has reviewed the swap execution facility core principles (“Core Principles”) as set forth in the CEA and has 

determined that the Program complies with the requirements of impartial access in Core Principle 2 and Commission 

Regulation 37.202 because all fees and any discounts will be applied in an impartial, fair, and non-discriminatory 

manner, and the Program will be made transparent to all participants. In compliance with Core Principle 2 and 

Commission Regulation 37.200, the Program does not incentivize manipulative trading or market abuse or impact NEX 

SEF’s ability to perform its trade practice and market surveillance obligations under the Act, and Market Regulation 

staff will continue to monitor trading to prevent manipulative trading and market abuse. The Program also complies with 

the requirements for monitoring and trade processing in Core Principle 4 and Commission Regulation 37.401, and the 

recordkeeping and reporting requirements in Core Principle 10 and Commission Regulations 37.1000 and 37.1001. 

NEX SEF has implemented systems to track Program participants’ transactions to ensure proper fee discounts are 

applied.

NEX SEF certifies that the revised Program complies with the requirements of the CEA and the rules and regulations 

promulgated thereunder. There were no substantive opposing views to this proposal. 

NEX SEF certifies that this submission has been concurrently posted on its website at 

http://www.cmegroup.com/market-regulation/rule-filings.html.

If you require any additional information regarding this submission, please contact the undersigned at 212-521-4609 or 

via email at CMEGSubmissionInquiry@cmegroup.com.

Sincerely,

/s/ Nirup Ramalingam

Chief Operating Officer

Attachments: Appendix A – Program (blacklined) (Confidential Treatment Requested)

Appendix B – Program (clean) (Confidential Treatment Requested)
2

APPENDIX A

CONFIDENTIAL TREATMENT REQUESTED

(ATTACHED UNDER SEPARATE COVER)
3

APPENDIX B

CONFIDENTIAL TREATMENT REQUESTED

(ATTACHED UNDER SEPARATE COVER)