trades in the case of clear clerical
error.

705 Record-keeping and Reporting

Conforming change — “BGC Broker”
to “Execution Specialist”

702a Trade Execution via RFQ

Conforming change — “BGC Broker”

Functionality to “Execution Specialist”; clarify
responsibilities of Execution
Specialists; add language referring to
provisions for confirmations and
objections.
802 Relation to Clearing Adds rule providing that a Participant
Organization must comply with margin
requirements.
804 Voluntary Clearing of Swaps Same addition as in rule 802.
805 Trades Not Accepted for Add provision prohibiting Participants
Clearing from requiring breakage agreements;
delete provision for submission of
rejected trades.
901 Violation of Law Add Customer to list of persons
prohibited from violating Act,
Regulations, or any other law
applicable to trading on Facility.
902 Rule Violation Add Customer to list of persons
covered by the Rule.
908 Abusive Trading Practice Adds prohibition of “accommodation
Prohibited trading, any other manipulative or

disruptive trading practice prohibited
by the Act or Commission
regulation”; add Customer to list of
persons to whom the Rule applies.

1002 Investigation Report

Clarify that the written report shall
include an analysis and
recommendation as to disciplinary
action.

1009(j) Hearings

Clarification of transcription of the
record,

1010(d) Decisions

Clarification of information required
in the decision.

1014 Minor Penalties

Specifies a minimum fine of $1,000;
add Authorized Customers and
Customers to list of persons to whom
the Rule applies.

1016 Action Against Non-
Participants

Delete language on finding of
likelihood of manipulation or threat to
integrity or liquidity.

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410 Compliance by Participants Add Customers to list of persons
agreeing to be bound by Rules.

505 Pre-Execution Discussions and | Conforming change ~ “BGC Broker”

Cross Trades to “Execution Specialist”
506 Allocation and Priority of Conforming change — “BGC Broker”
Orders; No Withholding of to “Execution Specialist”
Orders
510(c) and | Block Trades Clarifies that participants elect a
510 (d) Block Trade through trade entry
window or via an Execution
Specialist; clarifies that Block Trades
must be reported to the Facility as
soon as practicable after execution.
511(b) and | Public Disclosure of Data Clarifies operation of CFTC’s
S511(c) “embargo rule.”
512(e) Off-Facility Transactions by Add provision clarifying steps to be
Brokers taken by Clearing Participants with
respect to risk-based limits.

602 Trade Execution via Electronic | Clarify operation of Volume Match

Order Book Trading Facility and Customer Match
Trading Facility.

603 Orders Conforming change — “BGC Broker”
to “Execution Specialist”

604 Confirmations and Objections Clarifies that the confirmation is at
time of execution, that it is written and
that it legally supersedes prior
agreement; clarifies procedure to
object to a transaction confirmation,

606 Trade Cancellation and Price Adds language stating that

Adjustments adjustments shall be clear, fair and
publicly available and that notification
of a price adjustment will be made by
the Control Desk.

607(a) and | Assisted Order Entry Conforming change — “BGC Broker”
607(b) to “Execution Specialist”
607(c) Assisted Order Entry Add procedure for objection to
transaction confirmation.

702 Trade Execution via Voice Conforming change ~ “BGC Broker”

Functionality to “Execution Specialist”

703 Voice Trading Facility Conforming changes.

704 Confirmation of Voice Clarifies that the confirmation is at

Transactions and Objections

time of execution, that it is written
and that it legally supersedes prior
agreement; clarifies rules on
objections and authority to adjust

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1204 Emergency Power Clarifies delegation to CEO.

1209 Enforceability Incorporates the text of Rule 37,6,
1210 Audit Trail Incorporates the text of Rule 37.406
1306 Swaps Listed for Trading Incorporates procedures of

Commission, Rule 40.2 and 40.3.

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BGC Derivative Markets, L.P

Rule

Implementation Submission 2014-01

November 3, 2014

1.

The texts of the amended Rules are appended as Attachment A. Any additions are
underlined and any deletions are struck through.

The date of intended implementation for these rules is ten business days following the
filing of this submission.

Attached, please find a certification that: (1) these rules comply with the Commodity
Exchange Act (“Act”), and the Commission’s regulations thereunder; and (2) concurrent
with this submission, BGCDMLP posted on its website: (i) a notice of pending
certification ofthe rule amendments with the Commission; and (ii) a copy of this
submission.

A concise explanation and analysis of the operation, purpose, and effect of each of the
amended rules appears below.

. There were no opposing views expressed regarding these amended rules.

Confidential treatment is not requested.

CONCISE EXPLANATION AND ANALYSIS OF THE OPERATION, PURPOSE, AND

EFFECT OF THE RULE AMENDMENT AND ITS COMPLIANCE WITH APPLICABLE

PROVISIONS OF THE ACT, INCLUDING CORE PRINCIPLES AND THE
COMMISSION’S REGULATIONS THEREUNDER

Pursuant to Commission Rule 40.6(a)(7)(vi), the following is a concise explanation and analysis
of the operation, purpose, and effect of the amended rules, The attached amendments are
cumulative and in response to suggestions and guidance from the staff during the course of the

staff

review of the BECDML? application for registration as a Swap Execution Facility. These

amendments are either:

(1) technical corrections to align the rules more closely with the language of Commission
Rules; and/or
(2) amendments made in response to guidance of Commission staff.

The following chart identifies the changed rules and notes the effect of the change and an
explanation of the operation, purpose, and effect of the change.

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CERTIFICATIONS PURSUANT TO SECTION Sc OF THE COMMODITY EXCHANGE
ACT, 7 U.S.C. §7A-2 AND COMMODITY FUTURES TRADING COMMISSION RULE 40.6,
17 CFR. §40.6

Thereby certify that:

(1) the amended Rules above comply with the Commodity Exchange Act, and the
Commodity Futures Trading Commission’s regulations thereunder; and

(2) concurrent with this submission, BGC Derivative Markets, L.P. posted on its website:
(a) a notice of pending certification of the above Rules with the Commission; and (b)
a copy of this submission

PLS tee —

By: Michael Sulfaro
Title: Chief Compliance Officer
Date: October 20, 2014

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CONCISE EXPLANATION AND ANALYSIS OF THE OPERATION, PURPOSE, AND
EFFECT OF THE RULE AMENDMENT AND ITS COMPLIANCE WITH APPLICABLE
PROVISIONS OF THE ACT

Cover Page Clarify that the Rulebook applies to
Customers, including Authorized
Customers.
101 Execution Specialist Change “BGC Broker” to “Execution
Specialist”; clarify role of Execution
Specialists in connection with various
Trading Facility sessions.
101 Control Desk Delete language that Execution
Specialists may carry out Control
Desk functions.
101 Customer Match Trading Add definition
Facility
101 Participant Agreement Deleted
101 Regular Voice Trading Facility | Conforming change — “BGC Broker”
to “Execution Specialist”
101 Request for Quote (‘RFQ’) Deleted
Matching Trading Facility
101 Technology-Assisted Voice Conforming change — “BGC Broker”
Trading Facility to “Execution Specialist”
101 Voice Functionality Conforming change — “BGC Broker”
to “Execution Specialist”
101 Voice Trading Conforming change — “BGC Broker”
to “Execution Specialist”
101 Volume Match Trading Facility | Clarify that the auction is operated by
the Facility rather than the Control
Desk
206 Prohibition on Admission as Conforming change — “BGC Broker”
Participant to “Execution Specialist”
207(b) Restrictions on Trading by Clarify that provision applies to any
Officers and Employees corporate affiliate
207(c) Eligibility for Service on Boards | Amend the language to track the
and Committees language of Commission Rule 1.63(b)
207(d) Restrictions on Participation on | Add text conforming to language of
Board and Committees. Commission Rule 1.69;
Add proviso to business relationship
provision;

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Substitute CCO in place of CEO.

208 Restrictions on Participants with | Delete and reserve Rule 208.
an Ownership Interest

209(b)(i) Conflicts of interest Delete “knowingly;” conforming
change of “Clearing Privilege Holder”
to “Clearing Participant.”

209(b)(iv)(B) | Conflicts of interest Revise text to conform to Rule
1.69(b)(1) Gii)(B).

209(c)(ii) Conflicts of Interest Amend to track the language of

and (iii) 1.69(b)(2) (iii).
210 Chief Compliance Officer Adds rule incorporating text of
Commission Rule 37.1501

301(d) Status of Participants Delete subsection (d) relating to
existing customers,

304(a)(ix) | Denial of Admission Adds clarifying language that denial
for best interest of the Facility is
consistent with obligations of the
Facility under the Act.

307 Payment of Facility Fees Delete provision honoring existing fee
arrangements.

309(c) Market Data Clarifies that written notice for
marketing or business use of personal
information obtained for regulatory
obligations of the Facility is required.

403(a) Commission Reporting Clarify that reporting is “after

Requirement for Swaps execution;” clarify determination of
reporting counterparty.

403(b) Reporting of Errors Add provisions clarifying how errors
or omissions in publicly-disseminated
real-time data shall be corrected.

403(c) Commission Record Keeping Add provision specifying records

Requirement relating to trading in instruments
relating to indexes must be kept.

403(e) Facility Record-keeping Add language clarifying scope of

Requirements reasonable security policies.
403(g) Employee Supervision and Clarify provisions specifying
Training Participant responsibility for ensuring
training regarding Rules and trading
systems.

403(h) Rules Violation by Employees _| Delete Participant Agreement

405 Cooperation in Investigations Add Customer to list of persons who
shall cooperate with Facility
investigations.

407(d) Confidentiality of Trading Clarify scope of confidentiality rule

System

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