SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-137

Organization: NEX SEF Limited ("NEX SEF")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 03/13/23 Filing Description: Amendments to NEX SEF Limited 

Rulebook and Compliance Manual

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: See filing.

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 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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Christopher Bowen

Managing Director and Chief Regulatory Counsel

Legal Department

March 13, 2023

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: CFTC Regulation 40.6(a) Certification. Amendments to the NEX SEF Limited 

Rulebook and Compliance Manual.

NEX SEF Submission No. 23-137

Dear Mr. Kirkpatrick:

NEX SEF Limited (“NEX SEF”) is certifying to the Commodity Futures Trading Commission (“CFTC” or

“Commission”) amendments to Rule 105, 304, and 801 of the NEX SEF Rulebook and the NEX SEF

Compliance Manual (collectively, the “Rule Amendments”) effective on March 28, 2023 as more 

specifically described below.

1. NEX SEF Rulebook (Exhibit M):

• Amendments to Rule 105 (“Suspension of Trading”) to expand the NEX SEF Board authority 

to suspend trading in any instrument in the event of market volatility;

• Miscellaneous and clarifying amendments throughout the “Definitions” section and Rules 105, 

304 and 801 specifically related to CFTC SDR reporting requirements; and 

• Amendments to Rule 801 (“NDF Product Descriptions”) to clarifying terms and conditions of 

FX NDF products available on Facility, such as Holiday Calendar, Spot and Fixing Date terms

and well as miscellaneous administrative amendments. 

2. Compliance Manual (Exhibit O):

• Updates to collection of information section, reflecting the changes made to the electronic 

communications policy and approved methods of communication; and

• Update to Market Regulation Procedures that append the Compliance Manual, specifically 

Trade Practice Review Program (Exhibit O3) updated to clarify surveillance alert creation and 

identification. 

NEX SEF reviewed the Swap Execution Facility core principles (“Core Principles”) as set forth in the 

Commodity Exchange Act (“CEA” or “Act”) and identified that the Rule Amendments may have some 

bearing on Core Principles:

• Core Principle 2 – Compliance with Rules: As a result of the changes to the authority of the

Board and other similar changes, the Rule Amendments are being implemented to remain in 

satisfaction of this Core Principle. 

• Core Principle 4 – Monitoring of Trade and Trade Processing: As a result of the changes to 

the Trade Review Program, the Rule Amendments are being implemented to remain in 

satisfaction of this Core Principle.

Pursuant to Commission Regulation 37.3(b)(3), once a SEF is registered as such with the Commission, 

any amendments to Form SEF must be filed as a submission under Part 40 of the Commission’s 
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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regulations or as otherwise specified by the Commission.1 The Rule Amendments serve to amend 

previous NEX SEF submissions. As a result, NEX SEF is certifying the Rule Amendments to comply with 

the requirements set forth by the Commissions Regulation. 

Appendix A through Appendix D provide the Form SEF Exhibits. NEX SEF is requesting confidential 

treatment of the Compliance Manual and Trade Practice Review Program.

Pursuant to Section 5c(c) of the Commodity Exchange Act (the “Act”) and Regulations 37.3(b)3 and 40.6(a), 

NEX SEF hereby certifies that the Rule Amendments comply with the Act and the regulations 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-

299-2200 or via email at CMEGSubmissionInquiry@cmegroup.com.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel

Attachments: Appendix A: NEX SEF Rulebook (Form SEF Exhibit M) (blackline) (attached

 under separate cover)

Appendix B: NEX SEF Rulebook (Form SEF Exhibit M) (clean) (attached under

 separate cover)

Appendix C: NEX SEF Compliance Manual (Form SEF Exhibit O) (blackline)

 (Confidential Treatment Requested)

Appendix D: Trade Practice Review Program (Form SEF Exhibit O3) (blackline)

 (Confidential Treatment Requested)

1 See 78 Fed. Reg. 33476, at 33485 (June 4, 2013).
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Appendix A

NEX SEF Rulebook

(blacklined, provided under separate cover)

Appendix B

NEX SEF Rulebook

(clean, provided under separate cover)

Appendix C

(CONFIDENTIAL TREATMENT REQUESTED)

NEX SEF Compliance Manual

(blacklined, provided under a separate cover)

Appendix D

(CONFIDENTIAL TREATMENT REQUESTED)

NEX SEF

Trade Practice Review Program

(blacklined, provided under a separate cover)