#600795870v2

Bloomberg SEF LLC 731 Lexington Avenue Tel +1 212 318 2000

New York, NY 10022 bloombergsef.com

December 5, 2023

Submitted via Portal

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: CFTC Regulation 40.6(a) Certification. Product-Related Amendments to the BSEF LLC 

Rulebook

BSEF Submission No. 2023-R-18

Ladies and Gentlemen:

Bloomberg SEF LLC (“BSEF”) is certifying to the U.S. Commodity Futures Trading Commission (“CFTC” or 

“Commission”) the amending of Rule 1401 (“Rule Amendment”) to amend the contract to align with the 

UPI attributes and requirements. The Rule Amendment is effective on January 5, 2024. 

Exhibit A provides amendments to the applicable BSEF Rulebook Chapter in redline format.

A clean copy is attached hereto as Exhibit B.

Bloomberg SEF reviewed the swap execution facility core principles (“Core Principles”) as set forth in the 

Commodity Exchange Act (“Act” or “CEA”) and CFTC Regulations and identified that the amendment of 

terms in Rule 1401 may have some bearing on the following core principle: 

• Swaps Not Readily Susceptible to Manipulation (Core Principle 3): BSEF believes that Rule 

Amendments do not change the prior determination that swaps listed in Rule 1401 are not 

readily susceptible to manipulation.

Pursuant to Section 5c(c) of the Act and CFTC Regulations 40.6(a), BSEF hereby certifies that the Rule 

Amendments comply with the Act, including all regulations thereunder. There were no substantive 

opposing views to the proposal. 

BSEF certifies that this submission has been concurrently posted on the BSEF website at 

https://www.bloomberg.com/professional/product/sef-compliance/. 

Please contact the undersigned at (212) 617-7331 with any questions regarding this matter.

cc: Brian Robinson Division of Market Oversight, U.S. Commodity Futures Trading Commission
Exhibit A
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NDF-[currency pair][settlement currency][fixing date]

Contract Overview

Reference Currency

(i.e., Non-Deliverable

Currency)

A non-deliverable forward (NDF) is a forward contract which counterparties settle by exchanging in Settlement

Currency the difference between the Forward Rate agreed upon at the inception of the contract

and the ReferenceFixing Rate on the Fixing Date on an agreed notional amount. Forward Rate means the

rate of exchange from converting the unit currency into the quoted currency determined at the inception of

the contract. Fixing Rate means the rate of exchange from converting the unit currency into the quoted

currency determined on the Fixing Date.

• AOA Angolan Kwanza

• ARS Argentine Peso

• BRL Brazilian Real

• CLP Chilean Peso

• CNY Chinese Renminbi

• COP Colombian Peso

• CRC Costa Rican Colon

• DOP Dominican Republic Peso

• EGP Egyptian Pound

• GEL Georgian Lari

• GHS Ghanaian Cedi

• IDR Indonesian Rupiah

• INR Indian Rupee

• KES Kenyan Shilling

• KRW South Korean WonKZT Kazakh Tenge

• MYR Malaysian Ringgit (Please seeSee Notice to Participants 2017-3, which is posted on

BSEF’s website)

• NGN Nigerian Naira

• NPR Nepalese Rupee

• PEN Peruvian Nuevo sol

• PHP Philippine Peso

• PKR Pakistani Rupee

• PYG Paraguayan Guarani

• RUB Russian Ruble

• TWD Taiwan Dollar

• UAH Ukrainian Hryvnia

• UGX Ugandan Shilling

• UYU Uruguayan Peso

• VND Vietnamese Dong

RULE 101. RULE 1401. Foreign Exchange Contract – Non-Deliverable Forward

Reference Currency

Rate Source

For a specific currency, see Annex B

• Any source as described in Section 4.5A of ANNEX A to the 1998 FX and Currency Option Definitions

published by International Swaps and Derivatives Association, Inc and Trade Association for the Emerging

Markets; or

• “Bloomberg MID” or “BFX03” as described in Section 4.5B of ANNEX A to the 1998 FX and Currency

Option Definitions published by International Swaps and Derivatives Association, Inc and Trade Association

for the Emerging Markets; or

• “WM/RefinitivMID” or “WMR03” as described in Section 4.5B of ANNEX A to the 1998 FX and Currency

Option Definitions published by International Swaps and Derivatives Association, Inc and Trade Association

for the Emerging Markets.

Ticker
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Settlement Date

Settlement Currency

Specified settlement or payment date, as agreed by counterparties.

Notional amount, as agreed by counterparties.Forward Rate

Fixing/Expiration Date

Notional Currency

The date at whichthat the difference between the ReferenceForward Rate and the ForwardFixing

Rate is calculated and unadjusted date at which obligations stopped being effective.

Currency in which contract size is expressed in, as agreed by counterparties.

Final Contractual

Settlement Date

Unadjusted date by which all transfer of cash should take place and the counterparties no longer trade any

outstanding obligations under the contract, as agreed by counterparties.

See Settlement Currency List in Annex AAny ISO 4217 Currency or CNH. For CNH, the settlement

location is Hong Kong.

Settlement Method

Trading Conventions

Financially settled

Minimum Increment

Buy or Sell, which refers to the contract size expressed in notional currency.

Settlement Procedure Bilateral settlement performed in settlement currency.

Any value greater than zero (0).

Trading Hours

Forward Rate

14:00 Sunday to 17:00 Friday Eastern Time.

Currency exchange rate expressed as the amount of Reference Currency per unit of

Settlement Currency.

Block Size As set forth in Appendix F to Part 43 of the CFTC Regulations.

Speculative Limits

TradeEffective Date

As set in Part 150 of the CFTC Regulations.

Minimum Size

The unadjusted date onat which parties enterobligations come into the contracteffect.

Reportable Levels

Quoting Convention

and Minimum

Increment

As set in CFTC Regulation 15.03.

Notional amount, as agreed by counterparties.Any value greater than zero (0).
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SRD Suriname Dollar

ILS Israeli Shekel

GYD Guyana Dollar

NPR Nepalese Rupee

AED UAE Dirham

TZS Tanzanian Shilling

MZM Mozambique Metical

BMD Bermudian Dollar

THB Thai Baht

INR Indian Rupee

AFN Afghanistan Afghani

NZD New Zealand Dollar UAH Ukraine Hryvnia

ANG Neth. Ant. Guilder

AWG Aruban Guilder

BND Brunei Dollar ISK Iceland Krona

HKD Hong Kong Dollar

OMR Omani Rial

GMD Gambian Dalasi

UDI Mexican UDI

MZN New Mozambique Metical

GEL Georgia Lari

BOB Bolivian Boliviano

TJS Tajikistan Somoni

JMD Jamaica Dollar

MWK Malawi Kwacha

PAD Panamanian Balboa UGX Ugandan Shilling

GBP British Pound

BAM Bosnia-Herze Convrt Mrka

BRL Brazilian Real

SSP South Sudanese Pound

JOD Jordanian Dinar

HNL Honduras Lempira

PEN Peruvian New Sol

MUR Mauritius Rupee

USD US Dollar

NGN Nigeria Naira

BSD Bahamas Dollar

TND Tunisian Dinar

JPY Japanese Yen

Annex A

Settlement Currencies

PGK Papua N.G. Kina UYU Uruguay Peso

AOA Angolan Kwanza

BBD Barbados Dollar

BWP Botswana Pula

SOS Somali Shilling

KES Kenyan Shilling

HRK Croatia Kuna

PHP Philippines Peso

GNF Guinea Franc

UZS Uzbekistan Sum

NID New Iraqi Dinar

MRO Mauritania Ouguiya

BYR Belarus Ruble

TOP Tonga Pa’Anga

KGS Kyrgyzstan Som

MXN Mexican Peso

PKR Pakistani Rupee VEE Venezuela Essential Rate

BDT Banglaldesh Taka

BZD Belize Dollar

STD Sao Tome Dobra

KHR Cambia Riel

HTG Haiti Gourde

PLN Polish Zloty VEF Venezuelan Bolivar

NIO Nicaragua Cordoba

CAD Canadian Dollar

TRY Turkish Lira

KMF Comoros Franc

AMD Armenia Dram

PTE Portuguese Escudo VND Vietnamese Dong

ARS Argentine Peso

BGD Bulgarian Lev

CDF Congolese Franc

SLL Sierra Leone Leone

KRW South Korean Won

HUF Hungarian Forint

PYG Paraguay Guarani

GTQ Guatemala Quetzal

VUV Vanuatu Vatu

NLG Dutch Guilder

GHS Ghanaian cedi

CHF Swiss Franc

TTD Trinidad/Tobago Dol

KWD Kuwaiti Dinar

MYR Malaysian Ringgit

ROL Romanian Leu WAR Qatari Riyal

BHD Bahraini Dinar

CLP Chilean Peso

SVC El Salvador Colon

KYD Cayman Islands Dollar

IDR Indonesian Rupiah

RON New Romanian Leu

MVR Maldives Rufiyaa

WST Samoa (West) Tala

NOK Norwegian Krone

CNY China Renminbi (NDF)

TWD Taiwan Dollar

KZT Kazakhstan Tenge RSD Serbian Dinar XAF CFA Franc Beac

AUD Australian Dollar

BIF Burundi Franc
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XOF CFA Franc Bceao

DOP Dominican Repb.

CRC Costa Rican Colon

MDL Moldova Leu SDG New Sudanese Pound

LAK Laos Kip

ZAR S. African Rand

CZK Czech Koruna

LBP Lebanese Pound

DZD Algerian Dinar

LTL Lithuanian Litas

MGA Malagascy Ariary SDP Old Sudanese Pound

SBD Solomon Is. Dollar

ZMK Zambian Kwacha

RWF Rwanda Franc

XPF Pacific Island Franc

EGP Egyptian Pound (NDF)

RUB Russian Ruble (NDF)

MKD Macedonia Denar SEK Swedish Korna

XDR Special Drawing Rights

ZMW Zambia Kwacha

DJF Djibouti Franc

ERN Eritrean Nakfa

LVL Latvian Lats

MMK Myanmar Kyat SGD Singapore Dollar

SCR Seychelles Rupee

ZWR Zimbabwe Dollar

XCD East Caribbean Dollar

XSU Sucre

EUR Euro

CVE Cape Verde Escudo

MNT Mongolian Togrog SIT Slovenia Tolar

COP Colombian Peso

DKK Danish Krone

LKR Sri Lankan Rupee

FJD Fiji Dollar

MAD Moroccan Dirham

MOP Macau Pataca SKK Slovakia Koruna

SDD Sudanese Dinar

SAR Saudi Riyal

YER Yemeni Rial
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Brazilian Real

(BRL)

BRL OFFICIAL or

BRL02

Description

“BRL OFFICIAL” or “BRL02” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Chilean Peso

(CLP)

Argentine Peso

(ARS)

CLP DÓLAR OBS or

CLP10

Angolan

Kwanza (AOA)

“CLP DÓLAR OBS” or “CLP10” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

ARS MAE or ARS05

Currency

“ARS MAE” or “ARS05” as described in ANNEX A to the 1998 FX and

Currency Option Definitions effective on the Fixing Date published

by International Swaps and Derivatives Association, Inc and Trade

Association for the Emerging Markets.

Bloomberg MID or

BFX03

AOA Official or

AOA1

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Chinese

Renminbi (CNY)

CNY CNHHK or

CNY03

“AOA Official” or “AOA1” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“CNY CNHHK” or “CNY03” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

Spot FX Rate Sources

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

CNY SAEC or CNY01 “CNY SAEC” or “CNY01” as described in ANNEX A to the 1998 FX

Annex B

Exchange Rate Sources
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Bloomberg MID or

BFX03

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“Bloomberg MID” or “BFX03” as described in tANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

WM/Refinitiv MID or

WMR03

“WM/ RefinitivMID” or “WMR03” as described in ANNEX A to the

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

Colombian

Peso (COP)

Dominican

Republic Peso

(DOP)

Bloomberg MID or

BFX03

COP TRM or COP02

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

SFEMC CNY

INDICATIVE

SURVEY RATE or

CNY02

“COP TRM” or “COP02” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

WM/Refinitiv MID or

WMR03

“WM/ RefinitivMID” or “WMR03” as described in ANNEX A to the

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

“SFEMC CNY INDICATIVE SURVEY RATE” or “CNY02” as described in

ANNEX A to the 1998 FX and Currency Option Definitions effective

on the Fixing Date published by International Swaps and

Derivatives Association, Inc and Trade Association for the Emerging

Markets.

Egyptian Pound

(EGP)

EGP FEMF or EGP01

Bloomberg MID or

BFX03

“EGP FEMF” or “EGP01” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

Costa Rican

Colon (CRC)
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INR FBIL or INR01

WM/Refinitiv MID or

WMR03

“INR FBIL” or “INR01” as described in ANNEX A to the 1998 FX and

Currency Option Definitions effective on the Fixing Date published

by International Swaps and Derivatives Association, Inc and Trade

Association for the Emerging Markets.

“WM/ RefinitivMID” or “WMR03” as described in ANNEX A to the

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

SFEMC INR

INDICATIVE

SURVEY RATE or

INR02

“SFEMC INR INDICATIVE SURVEY RATE” or “INR02” as described in

ANNEX A to the 1998 FX and Currency Option Definitions effective

on the Fixing Date published by International Swaps and

Derivatives Association, Inc and Trade Association for the Emerging

Markets.

Georgian Lari

(GEL)

Ghanaian Cedi

(GHS)

Bloomberg MID or

BFX03

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Indonesian

Rupiah (IDR)

IDR JISDOR or

IDR04

“IDR JISDOR” or “IDR04” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

SFEMC IDR

INDICATIVE

SURVEY RATE or

IDR02

GHS WMR or GHS04

“SFEMC IDR INDICATIVE SURVEY RATE” or “IDR02” as described in

ANNEX A to the 1998 FX and Currency Option Definitions effective

on the Fixing Date published by International Swaps and

Derivatives Association, Inc and Trade Association for the Emerging

Markets.

“GHS WMR” or “GHS04” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

Indian Rupee

(INR)
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KES WMR or KES03

Bloomberg MID or

BFX03

“KES WMR” or “KES03” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Korean Won

(KRW)

KRW KFTC18 or

KRW02

“KRW KFTC18” or “KRW02” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Kazakhstani

Tenge (KZT)

Kenyan Shilling

(KES)

KRW KFTC30 or

KRW05

KES OFFICIAL or

KES02

“KRW KFTC30” or “KRW05” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

KZT KASE or KZT01

“KES OFFICIAL” or “KES02” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

SFEMC KRW

INDICATIVE

SURVEY RATE or

KRW04

“SFEMC KRW INDICATIVE SURVEY RATE” or “KRW04” as described

in ANNEX A to the 1998 FX and Currency Option Definitions

effective on the Fixing Date published by International Swaps and

Derivatives Association, Inc and Trade Association for the Emerging

Markets.

“KZT KASE” or “KZT01” as described in ANNEX A to the 1998 FX and

Currency Option Definitions effective on the Fixing Date published

by International Swaps and Derivatives Association, Inc and Trade

Association for the Emerging Markets.

Malaysian

Ringgit (MYR)

MYR KL REF or

MYR04

Bloomberg MID or

BFX03

“MYR KL REF” or “MYR04” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

SFEMC MYR

INDICATIVE

SURVEY RATE or

MYR02

“SFEMC MYR INDICATIVE SURVEY RATE” or “MYR02” as described

in ANNEX A to the 1998 FX and Currency Option Definitions

effective on the Fixing Date published by International Swaps and
#600795870v2

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Nigerian Naira

(NGN)

Nepalese

Rupee (NPR)

Paraguayan

Guarani (PYG)

Bloomberg MID or

BFX03

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

NGN NAFEX or

NGN03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

WM/Refinitiv MID or

WMR03

“WM/ RefinitivMID” or “WMR03” as described in ANNEX A to the

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

“NGN NAFEX” or “NGN03” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Philippine Peso

(PHP)

PHP BAPPESO or

PHP06

WM/Refinitiv MID or

WMR03

“PHP BAPPESO or “PHP06” as described in ANNEX A to the

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

“WM/ RefinitivMID” or “WMR03” as described in ANNEX A to the

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

Derivatives Association, Inc and Trade Association for the Emerging

Markets.

“SFEMC PHP INDICATIVE SURVEY RATE” or “PHP05” as

described in ANNEX A to the 1998 FX and Currency Option

Definitions effective on the Fixing Date published by International

Swaps and Derivatives Association, Inc and Trade Association for

the Emerging Markets.

Pakistani

Rupee (PKR)

Bloomberg MID or

PKR SBPK or PKR01

“Bloomberg MID” or “BFX03” as described in ANNEX A to the

Bloomberg MID or

BFX03

“PKR SBPK” or “PKR01” as described in ANNEX A to the 1998 FX and

Currency Option Definitions effective on the Fixing Date published

by International Swaps and Derivatives Association, Inc and Trade

Association for the Emerging Markets.
#600795870v2

SFEMC TWD

INDICATIVE

SURVEY RATE or

TWD04

Bloomberg MID or

BFX03

“SFEMC TWD INDICATIVE SURVEY RATE” or “TWD04” as described

in ANNEX A to the 1998 FX and Currency Option Definitions

effective on the Fixing Date published by International Swaps and

Derivatives Association, Inc and Trade Association for the Emerging

Markets.

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

TWD TAIFX1 or

TWD03

“TWD TAIFX1” or “TWD03” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Peruvian Sol

(PEN)

Russian Ruble

(RUB)

Bloomberg MID or

BFX03

RUB MOEX or

RUB05

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

PEN INTERBANK

AVE or PEN05

“RUB MOEX” or “RUB05” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Ukrainian

Hryvnia (UAH)

BFX03

UAH NBU or UAH04 “UAH NBU” or “UAH04” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“PEN INTERBANK AVE” or “PEN05” as described in ANNEX A to the

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

Bloomberg MID or

BFX03

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Ugandan

Shilling (UGX)

1998 FX and Currency Option Definitions effective on the Fixing

Date published by International Swaps and Derivatives Association,

Inc and Trade Association for the Emerging Markets.

UGX MID or UGX01 “UGX MID” or “UGX01” as described in ANNEX A to the 1998 FX

and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

Taiwan Dollar

(TWD)
#600795870v2

Bloomberg MID or

BFX03

Bloomberg MID or

BFX03

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

Vietnamese

Dong (VND)

VND FX or VND02 “VND FX” or “VND02” as described in ANNEX A to the 1998 FX and

Currency Option Definitions effective on the Fixing Date published

by International Swaps and Derivatives Association, Inc and Trade

Association for the Emerging Markets.

and Trade Association for the Emerging Markets.

Uruguayan

Peso (UYU)

Bloomberg MID or

BFX03

UYU OFFICIAL or

UYU01

“Bloomberg MID” or “BFX03” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.

“UYU OFFICIAL” or “UYU01” as described in ANNEX A to the 1998

FX and Currency Option Definitions effective on the Fixing Date

published by International Swaps and Derivatives Association, Inc

and Trade Association for the Emerging Markets.
Exhibit B
#600795870v2

Bloomberg SEF LLC 731 Lexington Avenue Tel +1 212 318 2000

New York, NY 10022 bloombergsef.com

 RULE 1401. Foreign Exchange Contract – Non-Deliverable Forward

Contract Overview A non-deliverable forward (NDF) is a forward contract which counterparties settle by exchanging in Settlement 

Currency the difference between the Forward Rate and the Fixing Rate on the Fixing Date on an agreed notional 

amount. Forward Rate means the rate of exchange from converting the unit currency into the quoted currency 

determined at the inception of the contract. Fixing Rate means the rate of exchange from converting the unit 

currency into the quoted currency determined on the Fixing Date.

Ticker NDF-[currency pair][settlement currency][fixing date]

Reference Currency 

(i.e., Non-Deliverable 

Currency)

• AOA Angolan Kwanza

• ARS Argentine Peso 

• BRL Brazilian Real 

• CLP Chilean Peso

• CNY Chinese Renminbi

• COP Colombian Peso

• CRC Costa Rican Colon

• DOP Dominican Republic 

Peso

• EGP Egyptian Pound

• GEL Georgian Lari

• GHS Ghanaian Cedi

• IDR Indonesian Rupiah

• INR Indian Rupee

• KES Kenyan Shilling

• KRW South Korean Won

• KZT Kazakh Tenge

• MYR Malaysian Ringgit (See Notice to Participants 2017-3 on BSEF’s 

website)

• NGN Nigerian Naira

• NPR Nepalese Rupee

• PEN Peruvian Nuevo sol

• PHP Philippine Peso

• PKR Pakistani Rupee

• PYG Paraguayan Guarani

• RUB Russian Ruble

• TWD Taiwan Dollar

• UAH Ukrainian Hryvnia

• UGX Ugandan Shilling

• UYU Uruguayan Peso

• VND Vietnamese Dong

Reference Currency 

Rate Source

• Any source as described in Section 4.5A of ANNEX A to the 1998 FX and Currency Option Definitions

published by International Swaps and Derivatives Association, Inc and Trade Association for the Emerging 

Markets; or

• “Bloomberg MID” or “BFX03” as described in Section 4.5B of ANNEX A to the 1998 FX and Currency Option 

Definitions published by International Swaps and Derivatives Association, Inc and Trade Association for the 

Emerging Markets; or

• “WM/RefinitivMID” or “WMR03” as described in Section 4.5B of ANNEX A to the 1998 FX and Currency 

Option Definitions published by International Swaps and Derivatives Association, Inc and Trade Association 

for the Emerging Markets.

Settlement Currency Any ISO 4217 Currency or CNH. For CNH, the settlement location is Hong Kong.

Quoting Convention Forward Rate

Minimum Increment Any value greater than zero (0).

Minimum Size Any value greater than zero (0).

Notional Currency Currency in which contract size is expressed in, as agreed by counterparties.

Trading Conventions Buy or Sell

Effective Date The unadjusted date at which obligations come into effect.

Fixing/Expiration Date The date that the difference between the Forward Rate and the Fixing Rate is calculated and unadjusted date at 

which obligations stopped being effective.

Final Contractual 

Settlement Date

Unadjusted date by which all transfer of cash should take place and the counterparties no longer trade any 

outstanding obligations under the contract, as agreed by counterparties.

Settlement Method Financially settled

Settlement Procedure Bilateral settlement performed in settlement currency. 

Trading Hours 14:00 Sunday to 17:00 Friday Eastern Time.

Block Size As set forth in Appendix F to Part 43 of the CFTC Regulations.

Speculative Limits As set in Part 150 of the CFTC Regulations.

Reportable Levels As set in CFTC Regulation 15.03.