Exhibit D

User Guide 360T SEF

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USER GUIDE 360T SEF

TEX MULTIDEALER TRADING SYSTEM

USER GUIDE 360T SWAP EXECUTION FACILITY 

FOR THE MARKET TAKER

27 SEPTEMBER, 2016

© 360 TREASURY SYSTEMS AG, 2015
User Guide 360T SEF

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1 INTRODUCTION

In July 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank” or 

the “Act”) was signed into U.S. federal law. The Act made changes to the financial regulatory 

environment in America as a way of promoting financial stability by, among other things, improving 

accountability and transparency in the financial system. Within the Act, Title VII concerns 

regulation of the over-the-counter swaps markets, which requires certain OTC derivative and FX 

instruments to be traded on a regulated SEF.

360 Trading Networks Inc. (360T) offers a SEF venue for such transactions captured under 

this definition. At present, this applies to FX options and FX non- deliverable forward and Swap 

(NDF and NDS) instruments traded by persons identified as U.S. entities or which fall under the 

definitions within the Act. 360T’s SEF services will enable clients to comply with their own Dodd 

Frank regulatory obligations and will retain the ability for clients to trade with greater transparency 

and enhanced control at every stage of the trading lifecycle.

Once a client is considered by 360T to be SEF relevant, users can only trade NDF, NDS and FX 

Options on the SEF. U.S. clients and entities trading with U.S. clients are blocked from trading 

these instruments if not enabled on the SEF. The required forms have therefore to be complete 

as well as the administrative information within the 360T administration tool.

This user manual describes the functionality available for the Market Participant trading as Market 

Taker under the 360T Swap Execution Facility (“360T SEF”). This means on one side the 

administrative functions to complete in the system prior to being able to trade under the 360T 

SEF, as well as the actual trading of the transactions falling under the regulation.

The 360T SEF platform is embedded in the 360T trading platform, so that an entity defined as 

trading NDF/NDS and FX Options under the SEF can still trade all other products under the non 

SEF platform. This user manual only describes the SEF relevant part. Please refer to the general 

360T user manuals for all non SEF business.

All SEF related items (platform functions, entity names, products etc.) are displayed in green color 

in the user interface and “SEF” in superscript.

For US participants, the provider list will only contain the counterparties which have also signed 

the SEF participation agreement and set up the SEF reporting parameters. Thus, you will make 

sure that you comply with the rules defined by the regulator.

For non US participants, the provider list can include US and non US counterparties. By showing 

the SEF label, the requester will be informed that a trade done with such provider will be reported 

under the regulation.

The following table shows under which conditions a trade will be considered as done on the SEF 

or done off the SEF.

Requester Provider SEF / OFF SEF

Is US Person Is US Person SEF

Is not US Person SEF

Is not US Person Is US Person SEF

Is not US Person OFF SEF
User Guide 360T SEF

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For all cases marked as SEF above, the following prerequisites must be fulfilled:

- Company has provided 360T with its LEI

- Company is SEF enabled by 360T

- SEF Reporting parameters have been keyed in both for Company and Traders.
User Guide 360T SEF

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2 SEF REPORTING PARAMETERS

Under the Dodd Frank Act regulation, required transaction creation data must be reported to a 

Swap Data Repository (SDR). In addition, data is reported to the National Futures Association 

(NFA) in order to conduct trade practice and market surveillance on behalf of the 360T SEF. The 

data transmitted to the SDR and the NFA are trade execution parameters as well as activity data 

in general about who is trading and what is traded. For this, some participant specific data needs 

to be completed by the company and users.

Once the SEF participation agreement has been signed with 360T, users will have been named 

to 360T’s support services and given the according Administration rights to complete required 

parameters.

The functionality “SEF Data” to enter the required data can then be found under the Administration 

menu.

Required fields are displayed in bold letters. As long as a field is shown in red colour the data is 

incomplete and can’t be saved.

Each company and user set up by 360T’s services on the platform is already associated to a 

country. Depending on that information, some fields might not be required. For example, if you 

are a UK entity but have signed the SEF participation agreement in order to be able to trade with 

US participants, then you will not be required to enter a SSN.

Once all data has been provided, the user will see all SEF enabled banks when opening a product 

definition for an NDF, NDS or FX Option.

If the data is incomplete, the user will not be able to trade on the SEF.

After completion of the SEF User data form, a trader can be disabled from SEF trading by setting 

the value of the “SEF enabled” field to “false”. 

Note that disablement of SEF trading only takes effect after the trader logs out and back into the 

application.
User Guide 360T SEF

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3 TRADING NDF/NDS AND FX OPTIONS AS REQUEST FOR

QUOTE ON THE SEF

Once SEF specific reporting data is defined, NDF, NDS and FX Options can be traded with the 

banks that have also completed the SEF on-boarding.

3.1 NDF

Non deliverable forwards are outright contracts for non-convertible foreign currencies, which are 

cash-settled by using the difference between the agreed forward rate and the spot rate on the 

fixing date, which is usually 2 working days before the settlement date.

The workflow supported in 360T’s SEF only concerns the execution of the NDF. Once NDF will 

be subject to clearing, further information will be completed in this manual. The settlement of the 

NDF always takes place offline between the counterparties.

An FX Non deliverable forward (NDF) product definition is opened after selecting the product NDF 

in the product selection area and after clicking on a price in one of the FX Live Pricing.

The product definition screen will already include predefined data corresponding to the selection 

in the live pricing screen. For example, the currency pair and the effective date correspond to 

that selection.

In order to effect a transaction, a user must specify the relevant currencies and the notional 

amount to be traded. The minimum notional amount that can be specified is the relevant 

currency’s smallest monetary unit. The maximum notional amount is restricted to a fixed digit 

length determined by 360T based upon credit and market risk considerations. 360T may change 

these parameters at any time. Users can access these parameters through the Trading System.

The Fixing Date will automatically be populated by the Trading System based on the spot date 

convention of the relevant currencies, and is generally two days before the value date.

The Trading System will automatically send the requester’s RFQ to the liquidity providers selected 

in advance by the requester on a disclosed basis. There is no minimum or maximum number of 

liquidity providers to whom RFQs may be sent.

3.2 NDS

Non-deliverable swaps traded on 360T SEF can be considered as two linked non-deliverable 

forwards with opposite actions.

The workflow supported in 360T’s SEF only concerns the execution of the NDS. Once NDF will 

be subject to clearing, further information will be completed in this manual. The settlement of the 

NDS always takes place offline between the counterparties.

An FX Non deliverable swap (NDS) product definition is opened after selecting the product NDS 

in the product selection area and after clicking on a price in one of the FX Live Pricing.

The product definition screen will already include predefined data corresponding to the selection 

in the live pricing screen. For example, the currency pair and the effective periods correspond to 

that selection.
User Guide 360T SEF

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In order to effect a transaction, a user must specify the relevant currencies and the notional 

amount to be traded. The minimum notional amount that can be specified is the relevant 

currency’s smallest monetary unit. The maximum notional amount is restricted to a fixed digit 

length determined by 360T based upon credit and market risk considerations. 360T may change 

these parameters at any time. Users can access these parameters through the Trading System.

The Fixing Date will automatically be populated by the Trading System based on the spot date 

convention of the relevant currencies, and is generally two days before the value date.

The Trading System will automatically send the requester’s RFQ to the liquidity providers selected 

in advance by the requester on a disclosed basis. There is no minimum or maximum number of 

liquidity providers to whom RFQs may be sent.

Different liquidity providers may be selected for different currencies. A requester can override this 

functionality if desired in order to select different liquidity providers on a trade by trade basis. 

Notification of execution is sent to be counterparties to a transaction, but is not sent to all users 

of the Trading System.

3.3 FX Options

360T supports requests in first generation options, calls and puts and combinations of 2 options 

(zero premium or standard risk reversal or a request with two legs), European and American style.

Option pricing can be requested for live pricing or with a separate spot delta hedge.

The premium value date is defaulted to the spot date for the currency in which the premium is to 

be paid, but can be changed by the user. The exercise date is automatically generated by the 

Trading System and is 1 or 2 business days before the relevant delivery date, depending on the 

spot date convention for the relevant currency pair.

The minimum notional amount that can be specified is the relevant currency’s smallest monetary 

unit. The maximum notional amount is restricted to a fixed digit length determined by 360T based 

upon credit and market risk considerations. 360T may change these parameters at any time. 

Users can access these parameters through the Trading System.

The Trading System will automatically send the requester’s RFQ to the liquidity providers selected 

in advance by the requester on a disclosed basis. There is no minimum or maximum number of 

liquidity providers to whom RFQs may be sent.

Different liquidity providers may be selected in advance for different currencies. A requester can 

override this functionality if desired in order to select different liquidity providers on a trade by 

trade basis. Notification of execution is sent to the counterparties to a transaction, but is not sent 

to all users of the Trading System.

3.3.1 Plain Vanilla FX Option / FX Risk Reversal / Zero Cost / Strategy option

In addition to plain vanilla, it is possible to request combinations of 2 options.

Pre-configured strategies to create a standard risk reversal or a zero-cost option are accessible 

over the menu Transaction.

To request a zero-premium option, the user requests the strike for the first option of the 

combination and the bank will quote the strike of the second option.
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In case of a standard risk reversal, the user will request a given strike for both options and the 

bank will quote the premium, similar to plain vanilla options

Further freely configurable combinations of two plain vanilla options can be requested via the 

menu Transaction, FX Options, Option Strategies. The product definition is similar to the risk 

reversal product definition, except that any combination of 2 options can be defined.
User Guide 360T SEF

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4 COMPETITIVE BIDDING AND TRADE EXECUTION

Once a product definition is complete, clicking to Send will send the request for quote stream to 

the swap dealers defined in the provider list.

Depending on the type of product, on the currency pair, the requested amount and tenor, prices 

will typically be returned immediately or within a few seconds. Very illiquid products or products 

requiring manual intervention on the market maker side might take much longer. In such cases, 

it might be necessary to extend the request time, which can be configured at the bottom right of 

each product definition.

The provided quotes are automatically sorted by best price on top. By clicking on the Counterpart 

column, the sorting can be changed to alphabetical sorting.

In case of 2-way requests, the quotes will be sorted by best spread on top (or in other words best 

bid and best offer).

By placing the mouse over a provided price, the details of the price (if available) and the P&L 

compared to the best price will be displayed in a tooltip.

A pre-trade mid-mark market rate (PTMMM) can be visualized over the tooltip as well.

The execution of the trade is triggered by clicking (or double-clicking depending on the user 

settings) on one of the displayed price.

Upon confirmation of the bank, a ticket automatically shows up, displaying all details of the 

executed trade, including competitive bids.

The Trading System will display a competitive bidding analysis which demonstrates whether an 

execution was done at the best price. It shows a full list of the quotes of all requested banks, 

sorted by best to worst and including a P&L compared to the best quote. It also includes banks 

that were requested but did not reply with a quote.

Optionally, a post-trade tab is displayed on the trade ticket, in order to complete the trade with 

customer specific fields required to book a trade post-trade in the requester’s back end system.
User Guide 360T SEF

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5 SPECIAL EXECUTION MODES

Two special execution modes are possible in the Trading System.

5.1 Multiple Executions

The objective of the multiple execution mode is to split a large trade amount to several banks. 

The request will then be executed in a row with several of the pricing banks.

If the Allow multiple execution was selected on the Transaction tab of the product definition, once 

the first bid is executed, the competitive bidding screen remains open, while the remaining banks 

continue to price. Further executions are then possible, until the user clicks on Finish, which then 

stops the request to the remaining banks.

5.2 Rollover and Early Settlement of Trades

NDF trades can be rolled over via the context menu in the dealblotter using the right mouse click 

or over the menu on the right of the dealblotter.

Rolling over an NDF automatically generates a new NDS based on the parameters of the rolled 

deal: near date of the NDS corresponds to the far date of the original deal; the same notional is 

assumed but can be modified. The request is then not only sent to the bank of the original rolled 

transaction, but simultaneously to other market makers as a new request for quote.
User Guide 360T SEF

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6 SEF ORDER BOOK

The SEF Order Book allows the SEF enabled users to place limit orders that can be viewed by 

all other users registered as SEF Participants with 360T.

All users can view all orders placed in the SEF Order Book. Execution is only possible between 

entities that have a counterparty relationship with each other.

Orders displayed in black can be executed. Orders displayed in grey with obfuscated Company 

name are only indicative, as they originate from market participants without a relationship to the 

entity looking at the order book.

Orders for NDF, NDS and FX Options are supported in the SEF Order Book. In order to place an 

order on the SEF Order Book, a user must specify the relevant product, currencies and the 

notional amount to be traded. The minimum notional amount that can be specified is the relevant

currency’s smallest monetary unit. The maximum notional amount is restricted to a fixed digit 

length determined by 360T based upon credit and market risk considerations. 360T may change 

these parameters at any time. Users can access these parameters through the Trading System.

360T does not automatically match orders and the execution remains under the control of the 

market participants. If an order is displayed as tradable (in black), the user can execute it without 

placing an opposite order in the user interface but by marking it, opening the context menu over 

the right mouse click and then selecting Execute; or by opening it with a double- click and then 

clicking the Execute button.

The SEF Order Book and the Request for Streamed quotes (RFS) process interact in the following 

way:

If a RFS matches one or several orders in terms of: Action, Currency Couple, Effective Date and 

Maturity Date, Fixing Reference/Expiry and the notional is equal to the amount in the Limit Order 

and also the notional currency is the same as in the limit order then the best executable limit rate 

will be displayed in the competitive bidding window. In addition the best indicative limit rate will 

also be displayed in the RFS window if it is better than or equal to the best executable limit rate. 

A rate is considered indicative (non executable), if no relationship to the company submitting the 

limit order exist.

Limit orders cannot be partially filled.

All orders placed in the SEF order book expire at the end of the trading day, i.e. at 5pm New York. 

A placed order can be canceled or amended by any user in the same company as the user who 

has entered the order.
User Guide 360T SEF

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7 CONTACTING 360T

Global Support

Phone: +49 69 900289-19

Fax: +49 69 900289-29

E-Mail: support@360t.com

EMEA Americas

Germany

360 Treasury Systems AG

Grueneburgweg 16-18

D-60322 Frankfurt am 

Main Phone: +49 69 900289-0

Fax: +49 69 900289-29

USA

360 Trading Networks, Inc.

521 5th Avenue, 38th Floor

New York, NY 10175

Phone: +1 212 776 2900

Asia Pacific

Singapore

360T Asia Pacific Pte. Ltd.

One George Street

#07-04 One George

Singapore 049145

Phone: +65 6325 9970

Fax: +65 6536 0662