LSEG FX SEF

Rule Book 

Effective Date: November 15, 2023

Document version 1.0

Date of issue: November 15, 2023

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© LSEG 2023. All rights reserved.

LSEG FX SEF (operated by Refinitiv US SEF LLC)_ by publishing this document, does not guarantee that 

any information contained herein is and will remain accurate or that use of the information will ensure 

correct and faultless operation of the relevant service or equipment. LSEG FX SEF , its agents and 

employees, shall not be held liable to or through any user for any loss or damage whatsoever resulting from 

reliance on the information contained herein.

This document contains information proprietary to LSEG FX SEF and may not be reproduced, disclosed, or 

used in whole or part without the express written permission of LSEG FX SEF . 

Any Software, including but not limited to, the code, screen, structure, sequence, and organization thereof, 

and Documentation are protected by national copyright laws and international treaty provisions. This 

manual is subject to U.S. and other national export regulations.

Nothing in this document is intended, nor does it, alter the legal obligations, responsibilities or relationship 

between yourself and Refinitiv as set out in the contract existing between us.

FX Global Code

The FX Global Code11 sets out globally recognized principles of good practice in the wholesale foreign 

exchange market (“FX Market”) and serves as an essential reference for market participants when 

conducting business in the FX Market and when developing and reviewing internal procedures.

The FX Global Code is supported by a Statement of Commitment that provides a means by which market 

participants can signal their intention to adopt, and adhere to, the FX Global Code. The signing of a 

Statement of Commitment represents that a market participant (i) has made an independent determination 

to support the FX Global Code, (ii) is committed to conducting its FX activities in accordance with the FX 

Global Code’s principles and (ii) confirms that it has taken appropriate steps, based on the size and

complexity of its activities, and the nature of its engagement in the FX Market, to align its activities with the 

FX Global Code principles.

In relation to SEF products, the SEF supports though does not mandate the signing of a Statement of 

Commitment by its Participants (as defined herein) as a condition of access to those products. Participants 

are responsible for deciding to what extent they should voluntarily adopt and implement the FX Global 

Code guidelines and are responsible for deciding whether their market counterparties need to confirm that 

they have signed a Statement of Commitment, and then for performing any associated due diligence. For 

example, a Participant can confirm directly with a potential market counterparty that such counterparty has 

signed a Statement of Commitment or use an FX Global Code public register for these purposes, such as 

the public register maintained by CLS.

2

Refinitiv (i.e., the SEF’s ultimate parent) has signed a Statement of Commitment to the FX Global Code, 

formally pledging adherence to the Code’s standards to promote integrity, fairness, transparency and the 

effective functioning of the global foreign exchange markets. Refinitiv has played an active role in the 

development of the FX Global Code through its membership in the Market Participants Group and through 

participation in regional committees, including the London Foreign Exchange Joint Standing Committee, the 

Federal Reserve Bank of New York Foreign Exchange Committee, the Tokyo Foreign Exchange Market 

Committee, the Canadian Foreign Exchange Committee, and the Australian Foreign Exchange Committee.

1 CLS, FX Global Code – public register, available at: https://www.globalfxc.org/fx_global_code.htm.

2 FX Global Code, available at: https://www.globalfxc.org/fx_global_code.htm.
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For the avoidance of doubt, nothing in the FX Global Code supersedes any provision(s) of the SEF Rules, 

CFTC Regulations or the Commodity Exchange Act (in each case, as defined herein).
Contents

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Contents

Introduction.................................................................................................................................................... 8

LSEG FX SEF Rulebook.............................................................................................................................. 8

LSEG FX Swap Execution Facility (SEF) Participant ................................................................................. 8

Chapter 1 Definitions.................................................................................................................................. 9

RULE 101 DEFINITIONS............................................................................................................................. 9

RULE 102 RULES OF CONSTRUCTION ............................................................................................. 19

Chapter 2 SEF Ownership and Governance .......................................................................................... 20

RULE 201 OWNERSHIP ....................................................................................................................... 20

RULE 202 BOARD................................................................................................................................. 20

RULE 203 OFFICERS ........................................................................................................................... 20

RULE 204 QUALIFICATIONS OF DIRECTORS, DISCIPLINARY PANEL MEMBERS, COMMITTEE 

MEMBERS AND OFFICERS..................................................................................................................... 21

RULE 205 CHIEF COMPLIANCE OFFICER......................................................................................... 21

RULE 206 STANDING COMMITTEES.................................................................................................. 23

RULE 207 REGULATORY OVERSIGHT COMMITTEE ....................................................................... 23

RULE 208 ADDITIONAL BOARD COMMITTEES AND SEF PANELS................................................. 24

RULE 209 EMERGENCY RULES......................................................................................................... 25

RULE 210 CONFLICTS OF INTEREST AND MISUSE OF MATERIAL, NON-PUBLIC INFORMATION

26

RULE 211 INFORMATION-SHARING AGREEMENTS........................................................................ 27

RULE 212 SERVICES AGREEMENT WITH A REGULATORY SERVICES PROVIDER .................... 28

RULE 213 SERVICES AGREEMENT WITH A TECHNOLOGY SERVICES PROVIDER.................... 28

Chapter 3 Participants.............................................................................................................................. 30

RULE 301 CRITERIA FOR BECOMING A PARTICIPANT................................................................... 30

RULE 302 PARTICIPANT APPLICATION PROCESS.......................................................................... 31

RULE 303 TRADING PRIVILEGES....................................................................................................... 32

RULE 304 ACCESS TO THE PLATFORM............................................................................................ 32

RULE 305 DUES, ASSESSMENTS AND FEES ................................................................................... 33

RULE 306 PARTICIPANT REPRESENTATIVES...................................................................................... 33

RULE 307 IDENTIFICATION OF AUTHORIZED PERSONS ............................................................... 34

RULE 308 RECORDING OF COMMUNICATIONS............................................................................... 34

RULE 309 NOTICES TO PARTICIPANTS............................................................................................ 34

RULE 310 COMMUNICATIONS BETWEEN THE SEF AND PARTICIPANTS .................................... 35

RULE 311 APPLICATION OF THE SEF RULES AND JURISDICTION ............................................... 35

RULE 312 DESCRIPTION OF PARTICIPANT’S STATUS ................................................................... 35

RULE 313 DEATH OR DISSOLUTION OF A PARTICIPANT............................................................... 36

RULE 314 WITHDRAWAL OF PARTICIPANT...................................................................................... 36
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RULE 315 COMPLIANCE WITH THE CEA........................................................................................... 36

RULE 316 SPONSORED ACCESS ...................................................................................................... 36

Chapter 4 SEF Services ........................................................................................................................... 38

RULE 401 REAL-TIME PUBLIC REPORTING...................................................................................... 38

RULE 402 REGULATORY REPORTING.............................................................................................. 38

RULE 403 MAINTENANCE OF BOOKS AND RECORDS BY THE SEF ............................................. 40

RULE 404 TRANSACTION CONFIRMATIONS .................................................................................... 41

RULE 405 AUDIT TRAIL PROGRAM.................................................................................................... 42

RULE 406 MONITORING OF TRADING AND TRADE PROCESSING................................................ 42

RULE 407 PUBLICATION OF TRADING INFORMATION.................................................................... 42

Chapter 5 Obligations of Participants .................................................................................................... 43

RULE 501 DUTIES AND RESPONSIBILITIES OF PARTICIPANTS.................................................... 43

RULE 502 REQUIRED DISCLOSURES TO THE SEF ......................................................................... 43

RULE 503 INSPECTIONS BY THE SEF............................................................................................... 44

RULE 504 MINIMUM REQUIREMENTS FOR PARTICIPANTS........................................................... 45

RULE 505 RECORDKEEPING REQUIREMENTS................................................................................ 45

RULE 506 CONFIDENTIALITY OF FINANCIAL AND OTHER INFORMATION................................... 46

RULE 507 AUTHORITY TO REPORT .................................................................................................. 46

RULE 508 BROKERS AND ACCOUNT MANAGERS........................................................................... 46

RULE 509 TREATMENT OF CUSTOMER FUNDS AND SECURITIES............................................... 46

RULE 510 DISCLOSURE REQUIREMENTS; KNOW YOUR COUNTERPARTY REQUIREMENTS.. 46

RULE 511 INFORMATION REGARDING ORDERS............................................................................. 47

RULE 512 CUSTOMER TYPE INDICATOR (CTI) CODES .................................................................. 47

RULE 513 CANCELED TRADES & AMENDED TRADE INFORMATION............................................ 47

Chapter 6 Supported Transactions......................................................................................................... 49

RULE 601 GENERAL ............................................................................................................................ 49

RULE 602 BLOCK TRADES.................................................................................................................. 49

RULE 603 PRIME BROKER TRADES.................................................................................................. 50

Chapter 7 Chapter 7 – Execution Methods ............................................................................................ 51

RULE 701 GENERAL ............................................................................................................................ 51

RULE 702 CENTRAL LIMIT ORDER BOOK (“CLOB”)......................................................................... 51

RULE 703 REQUEST FOR QUOTE PLATFORM (“RFQ PLATFORM”)............................................... 52

RULE 704 REQUEST FOR STREAM PLATFORM (“RFS PLATFORM”)............................................. 53

RULE 705 CONFIRMATION PROCEDURES AND RECORDS. .......................................................... 54

RULE 706 LEGAL CERTAINTY FOR SEF TRADES............................................................................ 54

RULE 707 POST-TRADE ANONYMITY................................................................................................ 54

Chapter 8 [Reserved]................................................................................................................................ 55

Chapter 9 Trading Practices and Business Conduct............................................................................ 56

RULE 901 SCOPE................................................................................................................................. 56

RULE 902 PROCEDURES.................................................................................................................... 56
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RULE 903 BUSINESS DAYS AND TRADING HOURS ........................................................................ 56

RULE 904 RULE VIOLATIONS............................................................................................................. 56

RULE 905 FRAUDULENT ACTS PROHIBITED ................................................................................... 57

RULE 906 FICTITIOUS, WASH OR NON-COMPETITIVE TRANSACTIONS PROHIBITED............... 57

RULE 907 MARKET DISRUPTION PROHIBITED................................................................................ 57

RULE 908 MANIPULATION AND FRAUDULENT CONDUCT PROHIBITED ...................................... 57

RULE 909 DISRUPTIVE TRADING PRACTICES PROHIBITED.......................................................... 58

RULE 910 ABUSIVE TRADING PRACTICES PROHIBITED................................................................ 58

RULE 911 PROHIBITION OF MISSTATEMENTS ................................................................................ 58

RULE 912 ACTS DETRIMENTAL TO WELFARE OF THE SEF PROHIBITED ................................... 58

RULE 913 ADHERENCE TO LAW........................................................................................................ 58

RULE 914 SUPERVISION..................................................................................................................... 58

RULE 915 MISUSE OF THE PLATFORM............................................................................................. 59

RULE 916 WITHHOLDING ORDERS PROHIBITED ............................................................................ 59

RULE 917 PRIORITY OF CUSTOMERS’ ORDERS............................................................................. 59

RULE 918 HANDLING OF CUSTOMER ORDERS............................................................................... 59

RULE 919 DISCLOSING ORDERS PROHIBITED................................................................................ 59

RULE 920 [RESERVED]........................................................................................................................ 60

RULE 921 PRE-ARRANGED AND NONCOMPETITIVE TRADES PROHIBITED ............................... 60

RULE 922 RESPONSIBILITY FOR CUSTOMER ORDERS................................................................. 60

RULE 923 DISCRETIONARY ORDERS ............................................................................................... 60

RULE 924 POSITION LIMITS................................................................................................................ 61

RULE 925 EXEMPTIONS FROM POSITION LIMITS........................................................................... 61

RULE 926 POSITION ACCOUNTABILITY............................................................................................ 61

RULE 927 PLATFORM ACCESS RESTRICTIONS.............................................................................. 61

RULE 928 PRE-EXECUTION CREDIT CHECKS ................................................................................. 62

RULE 929 RISK CONTROLS FOR TRADING...................................................................................... 62

RULE 930 [RESERVED]........................................................................................................................ 62

RULE 931 LIMITATION OF LIABILITY, NO WARRANTIES................................................................. 62

Chapter 10 Disciplinary Rules................................................................................................................... 65

RULE 1001 GENERAL ............................................................................................................................ 65

RULE 1002 INVESTIGATIONS AND INVESTIGATION REPORTS....................................................... 66

RULE 1003 DISCIPLINARY PANELS..................................................................................................... 67

RULE 1004 REVIEW OF INVESTIGATORY REPORT........................................................................... 68

RULE 1005 NOTICE OF CHARGES....................................................................................................... 68

RULE 1006 ANSWER TO NOTICE OF CHARGES................................................................................ 68

RULE 1007 SETTLEMENTS ................................................................................................................... 69

RULE 1008 RESPONDENT REVIEW OF EVIDENCE............................................................................ 70

RULE 1009 HEARINGS........................................................................................................................... 70

RULE 1010 DECISION OF HEARING PANEL........................................................................................ 72
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RULE 1011 SANCTIONS ........................................................................................................................ 72

RULE 1012 RIGHT TO APPEAL ............................................................................................................. 73

RULE 1013 SUMMARY FINES ............................................................................................................... 73

RULE 1014 EMERGENCY SUMMARY SUSPENSIONS AND OTHER SUMMARY ACTIONS............. 74

RULE 1015 RIGHTS AND RESPONSIBILITIES AFTER SUSPENSION OR TERMINATION............... 75

RULE 1016 NOTICE TO THE RESPONDENT, THE REGULATORY SERVICES PROVIDER AND THE 

PUBLIC 75

Chapter 11 Arbitration Rules..................................................................................................................... 76

RULE 1101 DISPUTES SUBJECT TO ARBITRATION........................................................................... 76

RULE 1102 INITIATING AN ARBITRATION CLAIM ............................................................................... 76

Chapter 12 Miscellaneous.......................................................................................................................... 78

RULE 1201 SEF PERSONNEL: TRADING AND MISUSE OF MATERIAL, NON-PUBLIC 

INFORMATION.......................................................................................................................................... 78

RULE 1202 NO ENDORSEMENT OF OPINIONS, RESEARCH OR RECOMMENDATIONS............... 79

RULE 1203 NOT A PARTY ..................................................................................................................... 79

RULE 1204 NO ADVICE.......................................................................................................................... 79

RULE 1205 GIFTS AND GRATUITIES ................................................................................................... 79

RULE 1206 MARKET DATA AND INTELLECTUAL PROPERTY........................................................... 79

RULE 1207 EXTENSION OR WAIVER OF RULES................................................................................ 80

RULE 1208 EFFECT OF AMENDMENT, REPEAL OR NEW RULE ...................................................... 81

RULE 1209 ANTITRUST CONSIDERATIONS........................................................................................ 81

RULE 1210 GOVERNING LAW, JURISDICTION AND DISPUTE RESOLUTION ................................. 81

Chapter 13 Contract Terms and Conditions ............................................................................................ 82

RULE 1301 NON-DELIVERABLE FORWARDS ..................................................................................... 82

RULE 1302 CROSS-CURRENCY NDF xxx ............................................................................................ 85

RULE 1303 FX OPTIONS........................................................................................................................ 88

Appendix AAppropriate Minimum Block Sizes........................................................................................ 90
Introduction

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Introduction

LSEG FX SEF Rulebook

This LSEG FX SEF Rulebook is subject to change without notice. The rules herein, and any revisions to be 

made, are conditional until approved or deemed approved by the CFTC.

LSEG FX Swap Execution Facility (SEF) Participant

By becoming a LSEG FX Swap Execution Facility (SEF) participant, accessing the platform or entering any 

order or submitting any contact into the platform, whether directly or through an intermediary, and without 

any need for any further action, undertaking or agreement, a participant and its authorized person(s), and 

the clients and customers of any participant, and any sponsored person, any isv, agree:

i. To be bound by, and comply with, the SEF rules and obligations, and applicable law, in each case to 

the extent applicable to it;

ii. To become subject to the jurisdiction of the SEF with respect to any and all matters arising from, 

related to, or in connection with, the status, actions or omissions of such person;

iii. To permit the SEF and any regulatory services provider authorized to act on behalf of the SEF to 

access any and all information relevant to activities related to the SEF business;

iv. To assist the SEF in complying with its legal and regulatory obligations, cooperate with the SEF and 

the CFTC in any inquiry, investigation, audit, examination or proceeding; and

v. That the SEF is authorized to provide information regarding such person to the regulatory services 

provider, the CFTC or any self- regulatory organization.
Chapter 1 Definitions

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Chapter 1 Definitions

RULE 101 DEFINITIONS

When used in this Rulebook the following terms shall have the respective meanings as follows:

Term Definition

“Account Manager” a Person that acts as an agent to buy or sell Swaps on the 

Platform in the name or on behalf of another Person. An 

Account Manager may also be a Participant and may be acting 

through another Account Manager if the Swap is intermediated.

“Affected Person” a SEF applicant whose admission application is declined or is 

conditioned or a Person whose status as a Participant is 

terminated, in each case as set forth in SEF Rule 302(g).

“Affiliate” with respect to any Person, any Person who, directly or 

indirectly through one or more intermediaries, Controls, is 

Controlled by, or is under common Control with, such other 

Person.

“Applicable Law” any foreign, federal (including the CFTC), state or other law, 

rule, regulation, interpretation or action of relevant regulatory 

organizations (including the National Futures Association) or 

self-regulatory organizations applicable to the access to and use

of the Platform, including the conduct of Swaps through the 

Platform.

“Appropriate Minimum Block Size” the minimum notional or principal amount established from time 

to time by the CFTC for a category of Swap that qualifies as a 

block trade pursuant to CFTC Regulation 43.6. The Appropriate 

Minimum Block Size is published by the CFTC or its designee 

from time to time in accordance with CFTC Regulations 43.6 

and 43.7 and is reproduced herein in Appendix A.

“Authorized Person” an employee or other person under Participant’s control 

designated by Participant or one of Participant’s administrators 

to be able to access and use the Platform and SEF Services on 

Participant’s behalf pursuant to Rule 306.A. An Authorized 

Person can also mean a computer or system accessing the SEF 

via a program interface on behalf of such Participant.

“Authorized Representative” any Person who is authorized by a Participant to represent the 

Participant in SEF matters pursuant to Rule 306.B.

“Block Trade” a privately negotiated Swap that (1) involves a Swap that is 

listed by the SEF; (2) occurs away from the Platform pursuant to 

the SEF Rules; (3) has a notional or principal amount at or 

above the Appropriate Minimum Block Size applicable to such 

Swap; and (4) is reported subject to the SEF Rules and the 

CFTC Regulations, including the appropriate time delay 

requirements set forth in CFTC Regulation § 43.5.

“Board” the Board of Directors of the SEF, which manages the SEF and 

is constituted from time to time in accordance with the SEF LLC 

Agreement.
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Term Definition

“Business Day” the twenty-four hour day, on all days except Saturdays, 

Sundays, and legal holidays, in New York, NY.

“CFTC” or “Commission” the U.S. Commodity Futures Trading Commission or any 

successor regulatory body.

“CFTC Regulations” the rules and regulations promulgated by the CFTC, as 

amended, as well as any guidance, no-action letters or other 

form of interpretation issued by the CFTC.

“Chief Compliance Officer” the individual appointed by the Board as the SEF’s Chief 

Compliance Officer. 

“Chief Executive Officer” the individual appointed by the Board as the SEF’s Chief 

Executive Officer.

“Cleared Swap” a Swap that is subject to the Clearing Requirement or any Swap 

that is intended by a Participant to be submitted to a Derivatives 

Clearing Organization for clearing contemporaneously with 

Execution.

“Clearing Member” a member of a Derivatives Clearing Organization that is 

authorized to clear trades in any or all Swaps for a Participant or 

its Clients or Customers.

“Clearing Requirement” the requirement to clear such swaps as the CFTC has 

determined must be cleared pursuant to Section 2(h) of the CEA 

and the CFTC’s rules and regulations promulgated thereunder.

“Client” a Person (including a Prime Broker) that: (i) granted in writing 

(either stand-alone or as part of a broader instrument) to an 

Account Manager investment authority or trading authority to 

send RFQs, to enter Orders and/or execute Swaps on behalf of 

and in the name of such Person; and (ii) is a Counterparty to a 

Swap.

“Commodity Exchange Act” or “CEA” the Commodity Exchange Act, as amended from time to time.

“Commodity Interest” has the meaning ascribed to it in CFTC Regulation § 1.3(yy).

“Confirmation Data” all of the terms of a Swap matched and agreed upon by the 

counterparties in confirming the Swap.

“Continuation Data” the data required to be reported to a Swap Data Repository in 

CFTC Regulation § 45.3(b), or any successor regulation thereto.

“Contract” any Swap, contract, agreement, or transaction approved for 

trading on the Platform pursuant to the SEF Rules.

“Contract Market” has the meaning ascribed to it in CFTC Regulation § 1.3(h), or 

any successor regulation thereto.

“Control” the possession, direct or indirect, of the power to direct or cause 

the direction of the management and policies of a Person, 

whether through the ownership of securities, by contract, or 

otherwise. The terms “controlling” or “controlled” shall have 

meanings correlative to the foregoing.
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Term Definition

“Counterparty” a Participant or a Participant’s Client or Customer whose Legal 

Entity Identifier is reported by the Platform to an SDR as a 

Counterparty to a trade.

“Creation Data” has the meaning ascribed to the term “Required swap creation 

data” in CFTC Regulation § 45.1.

“CTI Code” a customer type indicator code.

“Customer” has the meaning set forth in CFTC Regulation § 1.3(k).

“Customer Account” an account carried by a Participant on behalf of a Customer.

“Derivatives Clearing Organization” a derivatives clearing organization as defined in CFTC 

Regulation § 1.3(d), or any successor regulation thereto.

“Director” any member of the Board.

“Disciplinary Action” a disciplinary proceeding, summary imposition of fines, 

summary suspension or other summary action.

“Disciplinary Panel” the panel appointed by the Board at the recommendation of the 

Chief Compliance Officer to act in an adjudicative role and fulfill 

various adjudicative responsibilities and duties described in 

Chapter 10.

“DTCC” DTCC Data Repository (U.S.) LLC.

“Eligible Contract Participant” shall have the meaning set forth in Section 1a(18) of the CEA 

and the CFTC’s rules and regulations promulgated thereunder.
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Term Definition

“Emergency” any occurrence or circumstance which, in the opinion of the 

Board, or a person or persons duly authorized to issue such an 

opinion on behalf of the Board, under circumstances and 

pursuant to procedures that are specified by rule, requires 

immediate action, and which threatens, or may threaten, such 

things as the fair and orderly trading in, or the liquidation of or 

delivery pursuant to, any agreements, contracts, swaps or 

transactions, or the timely collection and payment of funds in 

connection with clearing and settlement by a Derivatives 

Clearing Organization, including:

(1) Any manipulative or attempted manipulative activity;

(2) Any actual, attempted, or threatened corner, squeeze, 

congestion, or undue concentration of positions;

(3) Any circumstances which may materially affect the 

performance of agreements, contracts, swaps or 

transactions, including failure of the payment system or 

the bankruptcy or insolvency of a Participant or any 

other Person;

(4) Any action taken by any Governmental Agency, or any 

other Registered Entity, board of trade, market or facility 

which may have a direct impact on trading or clearing 

and settlement; and

(5) Any other circumstance which may have a severe, 

adverse effect upon the functioning of a Registered 

Entity.

“Emergency Rules” temporary emergency procedures and rules implemented 

pursuant to Rule 209.

“End-User” a Participant that is not a “financial entity” as defined in CEA 

Section 2(h)(7)(C)(i), is using the Transaction to hedge or 

mitigate commercial risk as defined in CFTC Regulation § 

39.6(c), and provides or causes to be provided to a registered 

Swap Data Repository or, if no registered Swap Data Repository 

is available, the Commission, the information specified in CFTC 

Regulation § 39.6(b), or any successor regulation thereto.

“End-User Exception” the exception to the clearing requirement under CEA Section 

2(h)(7)(A), as amended from time to time.

“Execution” an agreement by the counterparties (whether orally, in writing, 

electronically, or otherwise) to the terms of the Contract that 

legally binds the counterparties to such terms under Applicable 

Law.

“FXall Group” FX Alliance, LLC and its affiliates.

“Futures Commission Merchant” has the meaning set forth in Section 1a(28) of the CEA and the 

CFTC’s rules and regulations promulgated thereunder.

“Government Agency” any governmental entity (including the United States, a State, or 

a foreign government).
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Term Definition

“Hearing Panel” the Disciplinary Panel responsible for adjudicating disciplinary 

cases pursuant to a notice of charges authorized by a Review 

Panel.

“Independent Software Vendor” or 

“ISV” 

a Person that makes available to Participants a system or 

platform offering smart order routing, front-end trading 

applications, an aggregator platform or a combination of the 

foregoing but that does not provide Participants the ability to 

effect transactions on such system or platform.

“Interested Person” has the meaning attributed to such term in Rule 210(a).

“Intermediary Agreement” an agreement between a Participant and a Sponsored Person, a 

Customer or Client of such Participant.

“ISV Agreement” an agreement entered into between the SEF and an ISV setting 

forth the rights and obligations of both parties.

“Legal Entity Identifier” the unique alphanumeric code issued to Participant by a CFTCdesignated utility or a registered Swap Data Repository, as set 

forth in 17 C.F.R. § 45.6 or any successor regulation thereto.

“Market Regulation Department” the Chief Compliance Officer and the individuals under the 

supervision of the Chief Compliance Officer who are responsible 

for enforcing these SEF Rules and conducting investigations of 

alleged violations of these Rules. As the term is used herein, the 

Market Regulation Department includes: (i) the SEF’s 

compliance staff dedicated to enforcing the SEF Rules and 

performing services directly related to the SEF’s compliance 

with Applicable Law; (ii) employees of other divisions of the SEF 

or its Affiliates who have certain regulatory responsibilities with 

respect to the SEF; and (iii) the staff of the Regulatory Services 

Provider providing services to the Company pursuant to a 

Regulatory Services Agreement.

“Major Swap Participant” shall have the meaning set forth in Section 1a(33) of the CEA 

and the CFTC’s rules and regulations promulgated thereunder.

“NFA” the National Futures Association.

“NFA Arbitration Program” the arbitration program established by the NFA designed for 

disputes between and among SEF Participants.

“Non-Cleared Swap” a Swap that is not a Cleared Swap, including, for the avoidance 

of doubt, a Swap where at least one Participant party is an EndUser and that party elects the End-User Exception.

“Notice to Participants” a communication sent by or on behalf of the SEF to all 

Participants as described in Rule 309.
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Term Definition

“Obligation” all obligations of a Participant as set forth in the SEF Rules, all 

rules adopted by the SEF in this Rulebook, the User Agreement, 

all Notices to Participants published by the SEF, interpretations, 

orders, procedures, resolutions, advisories, statements of policy, 

decisions, notices, manuals, directives of the SEF, and other 

requirements implemented by the SEF under the SEF Rules, 

including each term of a Contract, as well as any contractual 

obligations between a Participant, Account Manager, and the 

SEF, including the Participant Documentation and all 

amendments thereto.

“Officer” has the meaning attributed to such term in Rule 203.

“Option” has the meaning set forth in Section 1a(36) of the CEA and the 

CFTC’s rules and regulations promulgated thereunder.

“Order” either a bid or an offer for a Contract.

“Participant” a Person (other than an ISV, except to the extent permitted 

under the SEF Rules) that has agreed to the terms of these SEF 

Rules, the User Agreement, any Applicable Laws and 

regulations, and any and all other documents referenced herein, 

all as may be amended from time to time, and who has 

completed the User Agreement. Participants shall be granted 

Trading Privileges under the SEF Rules and shall be deemed to 

be members of the SEF for purposes of the CEA. The term 

Participant includes Authorized Person(s).

“Participant Documentation” the agreements (together with any applicable schedules, 

exhibits or appendices thereto required by the SEF) in form and 

substance acceptable to the SEF, that are required to be 

executed and delivered to the SEF before a Person may access 

the Platform, including, but not limited to the User Agreement as 

applicable and amended from time to time by the SEF.

“Permitted Transactions” any Transaction that is not subject to the trade execution 

requirement in Section 2(h)(8) of the CEA as well as any 

Transaction executed on the Platform where one of the 

counterparties properly elects to use the End-User Exception.

“Person” a natural person or a juridical entity.

“Platform” the interactive electronic trading facility and interface operated 

by or on behalf of the SEF as a Swap Execution Facility, 

including all components thereof, on and through which 

Participant may (i) submit Transaction Data to one or more other 

Participants and (ii) initiate and enter into Swaps. The Platform 

includes the SEF RFQ Platform, the SEF RFS Platform, and the 

SEF Central Limit Order Book.

“Pre-Execution Communication” a communication between two Persons for the purpose of 

discerning interest in the execution of a Swap prior to execution 

of the Swap on the SEF, including any communication that 

involves discussion of the size, side of market, or price of an 

Order or a potentially forthcoming Order; provided that any 

communication between two Persons that involves an 

agreement between the parties to a Swap that legally binds the 

parties to such Swap shall not be considered a Pre-Execution 

Communication.
Chapter 1 Definitions

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Term Definition

“Primary Economic Terms” all of the terms of a Swap matched or affirmed by the 

counterparties in verifying the Swap, including at a minimum 

each of the terms included in the most recent Federal Register 

release by the CFTC listing minimum primary economic terms 

for Swaps in the swap asset class in question. The CFTC's 

current lists of minimum primary economic terms for Swaps in 

each Swap asset class are found in appendix 1 to CFTC 

Regulation Part 45.

“Prime Broker” a Person that provides prime brokerage services and that has 

authorized an Account Manager to send RFQs, place Orders 

and/or enter into Swaps Transactions in the name and on behalf 

of such Person. Each Prime Broker must sign documentation as 

may be required by the SEF from time to time.

“Prime Broker Agreement” an agreement between a Prime Broker and a Participant that 

governs the performance and settlement of a Non-Cleared 

Swap, including any applicable credit support and default 

provisions.

“Prime Broker Trade” a Non-Cleared Swaps Transaction where one Counterparty is a 

Prime Broker and the other is a Participant with which the Prime 

Broker has a Prime Broker Agreement.

“Proprietary Account” has the meaning ascribed to it by CFTC Regulation § 1.3(y), or 

any successor regulation thereto.

“Proprietary Data and Personal 

Information” 

as to any Person, data or information that is related to, or that 

separately discloses, business transactions, market positions or 

trade secrets of such Person, but does not include Transaction 

Data.

“Refinitiv Group” Refinitiv and its affiliates.

“Registered Entity” (1) a board of trade designated as a contract market under 

section 5 of the CEA; 

(2) (2) a Derivatives Clearing Organization; 

(3) (3) a board of trade designated as a contract market 

under section 5f of the CEA;

(4) (4) a Swap Execution Facility registered under section 5h 

of the CEA; 

(5) a Swap Data Repository registered under section 21 of 

the CEA; and 

(6) with respect to a contract that the CFTC determines is a 

significant price discovery contract, any electronic trading 

facility on which the contract is executed or traded.

“Regulatory Oversight Committee” the committee of the Board constituted in accordance with Rule 

207.

“Regulatory Services Agreement” the agreement(s) between the SEF and the Regulatory Services 

Provider whereby certain functions mandated under the CEA, 

such as market surveillance and trade practice surveillance, are 

performed by to the Regulatory Services Provider.
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Term Definition

“Regulatory Services Provider” the organization, if any, which provides regulatory services to 

the SEF pursuant to a Regulatory Services Agreement.

“Reporting Counterparty” has the meaning ascribed to it by CFTC Regulation § 45.1, or 

any successor regulation thereto.

“Reporting Party” has the meaning ascribed to it by CFTC Regulation § 43.2, or 

any successor regulation thereto.

“Review Panel” the Disciplinary Panel responsible for determining whether a 

reasonable basis exists for finding a violation of the SEF Rules, 

and for authorizing the issuance of notices of charges against 

Persons alleged to have committed violations if the Review 

Panel believes that the matter should be adjudicated.

“SEF” or “the SEF” LSEG FX SEF, operated by Refinitiv US SEF LLC or any 

successor thereto, a Self-Regulatory Organization registered 

with the CFTC as a Swap Execution Facility.

“SEF Activity” business for which a Participant, Customer, Client or Sponsored 

Person is subject to the SEF Rules or which is purportedly 

conducted subject to the SEF Rules, including but not limited to 

the Execution of any Contract on the Platform.

“SEF LLC Agreement” the Limited Liability Company Agreement of the SEF, originally 

dated as of March 1, 2013, as the same may be amended from 

time to time.

“SEF Confirmation” has the meanings attributed to such term in Rule 404(a).

“SEF Official” any Director or Officer of, or individual employed directly by, the 

SEF, the Regulatory Services Provider or any individual 

rendering similar services to the SEF under an administrative or 

similar agreement.

“SEF Participant Application” the User Agreement, onboarding form, and any other 

agreements or information that are required to be executed and 

delivered to the SEF before a Person may access the Platform.

“SEF Proceeding” and “SEF Proceedings” have the meanings attributed to such terms in Rule 210(a).

“SEF Rules” all rules adopted, all Notices to Participants published by the 

SEF, the User Agreement, interpretations, orders, resolutions, 

advisories, statements of policy, decisions, manuals and 

directives of the SEF, and all amendments thereto.

“Self-Regulatory Action” has the meaning attributed to such term in Rule 210(a).

“Self-Regulatory Organization” shall, unless otherwise provided, have the meaning attributed to 

such term in CFTC Regulation § 1.3(ee), or any successor 

regulation thereto, and, in addition, shall include a Swap 

Execution Facility, Contract Market, and registered futures 

association, such as the NFA.
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Term Definition

“Sponsored Access” the process by which a Participant (“Sponsoring Participant”) 

provides Trading Privileges on the SEF to a market participant 

who is not a Participant (“Sponsored Person”). Sponsored 

Access takes multiple forms, including but not limited to: (a) 

“Sponsored Market Access”, where the Sponsoring Participant 

provides the connection to the SEF and the Sponsored Person’s 

orders pass through the Sponsoring Participant’s systems prior 

to reaching the Platform, and (b) “Direct Access”, where the 

Sponsored Person enters orders directly into the Platform via its 

own dedicated connection provided by the SEF under the 

auspices of and via an arrangement with the Sponsoring 

Participant, pursuant to Rule 316.

“Sponsored Person” shall mean an Eligible Contract Participant which has been 

provided electronic access to and Trading Privileges on the 

SEF by of a Sponsoring Participant pursuant to Rule 316, 

and who shall be subject to the jurisdiction of the SEF and 

comply with the SEF Rules as if such Sponsored Person 

was a Participant. For the avoidance of doubt, all 

references to Participant other than in Rules 302(a), 305 

and 314 shall include Sponsored Persons and their 

Authorized Persons.

“Sponsoring Participant” shall mean a Participant that has (i) designated a Sponsored 

Person to the SEF pursuant to the SEF Rules and (ii) extended 

Trading Privileges to such Sponsored Person. Upon acceptance 

of such designation by the SEF, the Sponsoring Participant shall 

be responsible for the obligations provided in Rule 316.

“Swap” or “Swaps” shall have the meaning set forth in Section 1a(47) of the CEA 

and the CFTC’s rules and regulations promulgated thereunder.

“Swap Data Repository” shall have the meaning set forth in Section 1a(48) of the CEA 

and the CFTC’s rules and regulations promulgated thereunder.

“Swap Dealer” shall have the meaning ascribed to it by CFTC Regulation § 

1.3(ggg), or any successor regulation thereto.

“Swap Execution Facility” shall have the meaning set forth in Section 1a(50) of the CEA 

and the CFTC’s rules and regulations promulgated thereunder.

“Swap Execution Facility Addendum” the addendum to the relevant agreement that Participant has 

entered into with a member of the FXall Group or Refinitiv Group 

which sets forth certain rights and obligations of the Participant 

and the SEF.

“Technology Services Agreement” the agreement(s) between the SEF and the Technology 

Services Provider whereby technology services are provided to 

the SEF.

“Technology Services Provider” the organization, if any, which provides technology services to 

the SEF pursuant to a Technology Services Agreement

“Terms Incorporated by Reference” has the meaning attributed to such term in Rule 404(a).

“Trade Communication” has the meaning attributed to such term in Rule 404(a).
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Term Definition

“Trading Hours” for any Business Day, the hours during which Orders may be 

placed on Platform, as shall be established, and may be revised 

from time to time, by the SEF pursuant to SEF Rule 903.

“Trading Privileges” the rights granted to a Participant to transmit Orders for a 

Contract through the Platform (including through an ISV).

“Transaction” any purchase or sale of any Contract made on the Platform or 

pursuant to the SEF Rules.

“Transaction Data” with respect to a Participant, data submitted by that Participant 

related to requests for quotes, offers, bids, pricing, matching, 

netting, settlement and similar data submitted through the 

Platform to one or more counterparties, as well as information 

that such Participant may upload to the Platform with respect to 

Transactions conducted otherwise than through the use of the 

Platform’s functionality, and messages sent in respect thereof.

“U.S. Person” a U.S. person as defined in the Commodity Exchange Act and 

the applicable regulations promulgated from time to time in 

connection therewith, or, in each case, under any interpretation 

or interpretative guidance issued in connection therewith or 

successor statute or rule.

“Unique Product Identifier” a unique identification of a particular level of the taxonomy of the 

product in an asset class or sub-asset class in question, as 

further described in CFTC Regulation § 43.4(f) and appendix A 

to CFTC Regulation Part 45. Such unique product identifier may 

combine the information from one or more of the data fields 

described in such appendix A.

“Unique Swap Identifier” shall have the meaning ascribed to it by CFTC Regulation § 

45.5, or any successor regulation thereto.

“User Agreement” the relevant agreement that Participant has entered into with a 

member of the FXall Group or Refinitiv Group, as amended by 

the Swap Execution Facility Addendum. For the purposes of the 

User Agreement with a member of the FXall Group, any 

reference to the “System” in the User Agreement shall include 

the SEF.

“User ID” a unique user identification number given to each Participant 

and each Authorized Person to enable such Participant or 

Authorized Person to access and use the Platform.

“Valuation Data” has the meaning ascribed to it in CFTC Regulation § 45.1, or 

any successor regulation thereto.

“Wash Transaction” a transaction entered into, or purported to be entered into, 

where the person knows or reasonably should know that the 

purpose of the order is to avoid taking a bona fide market 

position exposed to market risk.

“written” or “writing” printing, lithography, photography, and other modes of 

representing or reproducing words or data in a visible form, 

including electronic transmissions.
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RULE 102 RULES OF CONSTRUCTION

The following rules of construction shall apply to the SEF Rules:

a) the headings are for convenience only and do not affect the construction of the SEF Rules;

b) all references to time are to local time in New York, New York except where expressly provided 

otherwise;

c) words denoting a singular number include the plural number where the context permits and vice versa;

d) where the context permits or requires, any pronoun shall include the corresponding masculine, 

feminine and neuter forms;

e) references to statutory provisions include those provisions as amended from time to time, and any 

rules or regulations promulgated thereunder;

f) references to regulatory rulemakings, including but not limited to the CFTC Regulations, include those 

provisions as amended from time to time.
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Chapter 2 SEF Ownership and 

Governance

RULE 201 OWNERSHIP

The SEF is a Delaware limited liability company. The management and operation of the SEF is governed 

by the SEF LLC Agreement. Refinitiv US LLC owns all of the equity interest in the SEF.

RULE 202 BOARD

a) The Board shall manage the day to day business operations of the SEF in accordance with the SEF 

LLC Agreement and Applicable Law. The Board has the power and authority to call for review, and to 

affirm, modify, suspend or overrule any and all decisions and actions of standing committees or special 

committees of the Board or any panel of the Officers related to the day to day business operations of 

the SEF.

b) The Board may act only by the decision of an absolute majority in number of the Directors, either by 

vote at a meeting or by written consent without a meeting, or as otherwise set forth in the SEF LLC 

Agreement.

c) Each Director is entitled to indemnification pursuant to the SEF LLC Agreement with respect to matters 

relating to the SEF or otherwise relating to Refinitiv US LLC.

d) Each Director shall satisfy all fitness standards and otherwise meet all the requirements to serving as a 

director of a Swap Execution Facility under the CEA and CFTC Regulations.

e) The compensation of the non-executive members of the Board shall not be linked to the business 

performance of the SEF.

f) The Board shall have procedures, as may be further set forth in policies that the SEF may adopt, to 

remove a member from the Board where the conduct of such member is likely to be prejudicial to the 

sound and prudent management of the SEF.

RULE 203 OFFICERS

a) The Board shall appoint a Chief Executive Officer, a Chief Compliance Officer, and such other officers 

of the SEF (all of the foregoing, collectively, the “Officers”) as it may deem necessary or appropriate 

from time to time, in accordance with the SEF LLC Agreement.

b) Any Officer may also be a director, officer, partner or employee of the SEF or any of its Affiliates.

c) The Officers shall have such powers and duties in the management of the SEF as the Board may 

prescribe from time to time.

d) Each Director and Officer is entitled to indemnification pursuant to the SEF LLC Agreement with 

respect to matters relating to the SEF or otherwise relating to Refinitiv (Markets) LLC.
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RULE 204 QUALIFICATIONS OF DIRECTORS, 

DISCIPLINARY PANEL MEMBERS, 

COMMITTEE MEMBERS AND OFFICERS

a) A Director or Officer must meet the qualifications set forth from time to time in the SEF LLC 

Agreement.

b) An individual may not serve as a Director, or serve on a committee established by the Board or a 

Disciplinary Panel if the individual:

(1) within the prior three (3) years has been found, by a final decision in any action or proceeding 

brought in a court of competent jurisdiction, the CFTC, or any Self-Regulatory Organization, to 

have committed a disciplinary offense;

(2) within the prior three (3) years has entered into a settlement agreement in which any of the 

findings or, in the absence of such findings, any of the acts charged, included a disciplinary 

offense;

(3) is currently suspended from trading on a Contract Market, is suspended or expelled from 

membership in a Self- Regulatory Organization, is serving any sentence or probation, or owes 

any portion of a fine or penalty related to either:

i. a finding of a disciplinary offense by a final decision in any action or proceeding brought in 

a court of competent jurisdiction, the CFTC, or any Self-Regulatory Organization; or

ii. a settlement agreement in which any of the findings or, in the absence of such findings, 

any of the acts charged included a disciplinary offense;

(4) is currently subject to an agreement with the CFTC or Self-Regulatory Organization not to apply 

for registration with the CFTC or for membership in the Self-Regulatory Organization;

(5) is currently, or within the past three (3) years has been, subject to a revocation or suspension of 

registration by the CFTC;

(6) has been convicted of a felony listed in section 8a(2)(D)(ii) through (iv) of the CEA; or

(7) is currently subject to a denial, suspension or disqualification from serving on a disciplinary 

committee, arbitration panel or governing board of any self-regulatory organization as that term 

is defined in section 3(a)(26) of the Securities Exchange Act of 1934.

c) Any Director, Officer, member of a committee established by the Board, any member of a Disciplinary 

Panel, any individual nominated to serve in any such role, or any individual authorized by a Hearing 

Panel to take summary action shall immediately notify the Chief Executive Officer if such individual 

meets one or more of the criteria in Rule 204(b).

d) For purposes of Rule 204(b), the terms “disciplinary offense,” “final decision,” and “settlement 

agreement” have the meanings set forth in CFTC Regulation § 1.63(a) or any successor regulation.

RULE 205 CHIEF COMPLIANCE OFFICER

a) The Chief Compliance Officer shall have the following duties:

(1) Overseeing and reviewing the SEF’s compliance with Section 5h of the CEA and any related 

rules adopted by the CFTC;

(2) In consultation with the Board, resolving any conflicts of interest that may arise including:

i. Conflicts between business considerations and compliance requirements;
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ii. Conflicts between business considerations and the requirement that the SEF provide fair, 

open, and impartial access as set forth in CFTC Regulation § 37.202 or any successor 

regulation; and;

iii. Conflicts between the SEF’s management and members of the Board;

(3) Establishing and administering written policies and procedures reasonably designed to prevent 

violation of the CEA and any rules adopted by the CFTC;

(4) Taking reasonable steps to ensure compliance with the CEA and CFTC regulations;

(5) Establishing procedures for the remediation of noncompliance issues identified by the Chief 

Compliance Officer through a compliance office review, look-back, internal or external audit 

finding, self-reported error, or validated complaint;

(6) Establishing and following appropriate procedures for the handling, management response, 

remediation, retesting, and closing of noncompliance issues;

(7) Establishing and administering a compliance manual designed to promote compliance with the 

applicable laws, rules, and regulations and a written code of ethics designed to prevent ethical 

violations and to promote honesty and ethical conduct;

(8) Supervising the SEF’s self-regulatory program with respect to trade practice surveillance; 

market surveillance; real-time market monitoring; compliance with audit trail requirements; 

enforcement and disciplinary proceedings; audits, examinations, and other regulatory 

responsibilities with respect to Participants, Customers and Clients (including ensuring 

compliance with, if applicable, financial integrity, financial reporting, sales practice, 

recordkeeping, and other requirements); and

(9) Supervising the effectiveness and sufficiency of any regulatory services provided to the SEF by 

the Regulatory Services Provider or other Registered Entity in accordance with CFTC 

Regulation § 37.204 or any successor regulation.

b) The Chief Compliance Officer shall have the authority and resources to develop and enforce policies 

and procedures necessary to fulfill the duties set forth herein as well as set forth in the CEA and CFTC 

regulations.

c) The Chief Compliance Officer shall report directly to the Board. The Chief Compliance Officer shall 

meet with the Board at least annually and shall meet with the Regulatory Oversight Committee at least 

quarterly. The Chief Compliance Officer shall provide any information regarding the regulatory program 

of the SEF operated by the SEF that is requested by the Board or the Regulatory Oversight 

Committee.

d) The Board shall approve the compensation of the Chief Compliance Officer.

e) The Chief Compliance Officer shall have the authority to inspect the books and records of all 

Participants and the authority to require any Participant to appear before him or her and produce its 

books and records and answer questions regarding alleged violations of the SEF Rules, at the time, 

place and in the manner it designates. The Regulatory Services Provider may also perform these 

functions on behalf of the Chief Compliance Officer.

f) The Chief Compliance Officer may not be disqualified from registration pursuant to Sections 8a(2) or 

8a(3) of the CEA.

g) The Chief Compliance Officer shall annually prepare and sign a report pursuant to the requirements in 

Section 37.1501(e) and 37.1501(f) which shall contain:

(1) A description of the SEF's written policies and procedures, including the code of ethics and 

conflict of interest policies;

(2) A review of applicable CFTC Regulations and each subsection and core principle of section 5h 

of the CEA, that, with respect to each:
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i. Identifies the policies and procedures that are designed to ensure compliance with each 

subsection and core principle, including each duty specified in section 5h(f)(15)(B) of the 

CEA;

ii. Provides a self-assessment as to the effectiveness of these policies and procedures; and;

iii. Discusses areas for improvement and recommends potential or prospective changes or 

improvements to its compliance program and resources;

(3) A list of any material changes to compliance policies and procedures since the last annual 

compliance report;

(4) A description of the financial, managerial, and operational resources set aside for compliance 

with respect to the CEA and CFTC Regulations, including a description of the SEF’s selfregulatory program's staffing and structure, a catalogue of investigations and disciplinary actions 

taken since the last annual compliance report, and a review of the performance of disciplinary 

committees and panels;

(5) A description of any material compliance matters, including noncompliance issues identified 

through a compliance office review, look-back, internal or external audit finding, self-reported 

error, or validated complaint, and an explanation of how they were resolved;

(6) A certification by the Chief Compliance Officer that, to the best of his or her knowledge and 

reasonable belief, and under penalty of law, the annual compliance report is accurate and 

complete.

h) Removal of the Chief Compliance Officer shall require the approval of a majority of the SEF’s Board.

i) If the Chief Compliance Officer is removed from his or her post, the SEF shall notify the CFTC of the 

removal within two business days.

RULE 206 STANDING COMMITTEES

a) The Board shall initially have one standing committee: the Regulatory Oversight Committee. The 

Board may from time to time constitute and appoint in accordance with the SEF LLC Agreement such 

additional standing committees of the Board as it may from time to time deem necessary or advisable.

b) Each member of such standing committees must be a Director, one of whom the Board shall designate 

as the chairperson of each standing committee.

c) Each standing committee shall assist in the supervision, management and control of the affairs of the 

SEF within its particular area of responsibility, subject to the authority of the Board.

d) Subject to the authority of the Board, each standing committee shall determine the manner and form in 

which its proceedings shall be conducted. Each standing committee may act only by the decision of an 

absolute majority in number of the members of such committee, by vote at a meeting or by unanimous 

written consent without a meeting. The Board has the authority to overrule the decisions of a standing 

committee.

RULE 207 REGULATORY OVERSIGHT COMMITTEE

a) The Regulatory Oversight Committee of the Board shall consist of at least two Directors appointed 

from time to time by the Board. In the event of a tie between the two Directors, the Chief Compliance 

Officer may vote on any matter for which she/he does not have a potential or actual conflict of interest.

b) Each member of the Regulatory Oversight Committee shall serve for a term of two calendar years from 

the date of their appointment or for the remainder of their term as a Director, and until the due 
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appointment of his or her successor, or until his or her earlier resignation or removal, with or without 

cause, as a member of the Regulatory Oversight Committee or as a Director. A member of the 

Regulatory Oversight Committee may serve for multiple terms.

c) The Regulatory Oversight Committee shall oversee the SEF’s regulatory program on behalf of the 

Board. The Board shall delegate sufficient authority, dedicate sufficient resources, and allow sufficient 

time for the Regulatory Oversight Committee to fulfill its mandate. It shall make such recommendations 

to the Board as will, in its judgment; best promote the interests of the SEF. The Regulatory Oversight 

Committee shall also have such other powers and perform such other duties as set forth in the SEF 

Rules and as the Board may delegate to it from time to time.

d) Without limiting the generality of the foregoing, the Regulatory Oversight Committee shall have 

authority to:

(1) Monitor the regulatory program of the SEF for sufficiency, effectiveness, and independence;

(2) Oversee all facets of the regulatory program, including:

i. Trade practice and market surveillance; audits, examinations, and other regulatory 

responsibilities with respect to Participants (including compliance with, if applicable, 

financial integrity, financial reporting, sales practice, recordkeeping, and other 

requirements); and the conduct of investigations;

ii. Reviewing the size and allocation of the regulatory budget and resources, and the 

number, hiring, termination, and compensation of regulatory personnel;

iii. Reviewing the performance of the Chief Compliance Officer and making 

recommendations with respect to such performance to the Board;

iv. Recommending changes that would ensure fair, vigorous, and effective regulation; and

v. Reviewing all regulatory proposals prior to implementation and advising the Board as to 

whether and how such changes may impact regulation.

e) The Regulatory Oversight Committee reports to the Board.

RULE 208 ADDITIONAL BOARD COMMITTEES AND 

SEF PANELS

a) In addition to the standing committees described in Rule 206, the Board may from time to time 

constitute and appoint, in accordance with the SEF LLC Agreement, special committees of the Board 

and designate their composition, responsibilities and powers. Each member of such special 

committees must be a Director.

b) The SEF may create panels of the SEF, for such purposes as may from time to time be necessary or 

advisable. Members of each such panel may be Directors or Participants (if individuals) or any of a 

Participant’s Authorized Persons (if an entity) or such other individuals as may be qualified to serve on 

such panel.

c) Except as otherwise specifically provided in the SEF Rules, the members of any additional committee 

or panel shall be appointed as determined by the Board. The Board shall designate the chairperson of 

such additional committee or panel.

d) Each additional committee or panel shall assist in the supervision, management and control of the 

affairs of the SEF within its particular area of responsibility.

e) Subject to the authority of the Board, each additional committee or panel shall determine the manner 

and form in which its proceedings shall be conducted. Each additional committee or panel may act 
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only by the decision of an absolute majority in number of the members of such committee or panel, 

either by vote at a meeting or by unanimous written consent without a meeting.

RULE 209 EMERGENCY RULES

a) During an Emergency, the SEF may implement Emergency Rules, subject to the applicable provisions 

of the CEA and CFTC Regulations. Pursuant to the Emergency Rules, the SEF will have the authority 

to intervene as necessary to maintain markets with fair and orderly trading and to prevent or address 

manipulation or disruptive trading practices, whether the need for intervention arises exclusively from 

the SEF’s market or as part of a coordinated, cross-market intervention.

Emergency Rules may require or authorize the SEF, the Board, any committee of the Board, the Chief 

Executive Officer, the Chief Compliance Officer, or any other Officer to take actions necessary or 

appropriate to respond to the Emergency, including, but not limited to, the following actions:

(1) imposing or modifying position limits,

(2) imposing or modifying price limits;

(3) imposing or modifying intraday market restrictions;

(4) imposing special margin requirements, including working with a Derivatives Clearing 

Organization to impose special margin requirements;

(5) ordering the liquidation or transfer of open positions in any Contract;

(6) ordering the fixing of a settlement price;

(7) extending or shortening the expiration date or the Trading Hours;

(8) suspending or curtailing trading in any Contract;

(9) transferring customer Contracts and the margin, or altering any Contract’s settlement terms or 

conditions;

(10) if applicable, providing for the carrying out of such actions through its agreements with the 

Regulatory Services Provider; or

(11) taking market actions as may be directed by the CFTC.

b) Before any Emergency Rule may be adopted and enforced, a required vote of the Regulatory 

Oversight Committee must approve the enforcement of such Emergency Rule at a duly convened 

meeting. Directors may attend such a meeting by teleconference. If the Chief Executive Officer or 

Chief Compliance Officer determines that Emergency Rules must be implemented with respect to an 

Emergency before a meeting of the Regulatory Oversight Committee can reasonably be convened, 

then the Chief Executive Officer or Chief Compliance Officer shall have the authority, without Board or 

Committee action, to implement any Emergency Rules with respect to such Emergency that he or she 

deems necessary or appropriate to respond to such Emergency. In such circumstances, the Chief 

Executive Officer or Chief Compliance Officer must convene a meeting as soon as practicable.

c) Whenever the SEF, the Board, any committee of the Board, the Chief Executive Officer or Chief 

Compliance Officer takes actions necessary or appropriate to respond to an Emergency, a duly 

authorized person of the SEF, where possible, will post an announcement in a Notice to Participants. 

When the Board, any committee of the Board, the Chief Executive Officer or the Chief Compliance 

Officer determines that the Emergency has been reduced sufficiently to allow the SEF to resume 

normal functioning, any such actions responding to an Emergency will be terminated.

d) In situations where a Swap is traded on more than one Swap Execution Facility, emergency action to 

liquidate or transfer open interest must be directed, or agreed to, by the CFTC or CFTC staff, and the 

SEF will use reasonable efforts to coordinate with any Derivatives Clearing Organization that has 
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cleared the Swap and any other Swap Execution Facilities where such Swap is traded prior to 

mandating the liquidation or transfer of such Swap.

e) The SEF will use reasonable efforts to notify the CFTC prior to implementing, modifying or terminating 

an Emergency Rule. If such prior notification is not possible or practicable, the SEF will notify the 

CFTC at the earliest possible time after implementation, modification or termination, but in no event 

more than twenty-four hours after implementation, modification or termination.

f) Upon taking any action in response to an Emergency, the SEF will document the decision- making 

process and the reasons for taking such action. Information on any regulatory action taken pursuant to 

the Emergency Rules will be included in a submission of a certified rule to the CFTC. All such 

documentation will be kept for at least five years, two years in a readily accessible location, following 

the date on which the Emergency ceases to exist or to affect the SEF, and all such documentation will 

be provided to the CFTC upon request.

g) Upon taking any action in response to an Emergency, the SEF will promptly notify the CFTC of the 

SEF’s exercise of the Emergency Rules, explaining its decision-making process, the reasons for using 

its emergency authority, and how conflicts of interest were minimized, including the extent to which the 

SEF considered the effect of its emergency action on the underlying markets and on markets that are 

linked or referenced to the contracts traded on its facility, including similar markets on other trading 

venues.

RULE 210 CONFLICTS OF INTEREST AND MISUSE OF 

MATERIAL, NON-PUBLIC INFORMATION

a) A Director, Officer, Disciplinary Panel member or other Person authorized to exercise the SEF’s 

authority concerning any inquiry, investigation, disciplinary proceeding, summary suspension, or other 

summary actions (any such action, a “SEF Proceeding” and, collectively, “SEF Proceedings”), or 

Emergency actions taken pursuant to Rule 209 or emergency disciplinary action taken pursuant to 

Rule 1014 (each such SEF Proceeding or Emergency action, a “Self-Regulatory Action”) who 

knowingly has a “material conflict of interest” between his or her position as a Director, Officer, panel 

member or exercise of authority concerning a Self-Regulatory Action and his or her personal interests 

(each, an “Interested Person”) may not participate in any deliberations or vote of the Board 

Committee, panel or exercise any authority with respect to such Self-Regulatory Action involving his or 

her personal interest, except as described in Rule 210(d).

b) For purposes of Rule 210(a), a “material conflict of interest” means a Director, Officer, Disciplinary 

Panel Member or other Person:

(1) being named as a respondent or potential respondent in the Self-Regulatory Action;

(2) being an employer, employee, fellow employee or an Affiliate of a respondent or potential 

respondent in the Self- Regulatory Action;

(3) having any significant, ongoing business relationship with a respondent or potential respondent 

in the Self-Regulatory Action;

(4) having a family relationship with a respondent or potential respondent in a Self-Regulatory 

Action (including the individual’s spouse, co-habitator, former spouse, parent, step-parent, child, 

step-child, sibling, step-brother, step- sister, grandparent, grandchild, uncle, aunt, nephew, 

niece, father-in-law, mother-in-law, brother-in-law or sister-in- law);

(5) having a direct and substantial financial interest in the result of the deliberations or vote based 

upon either exchange or non-exchange positions (as referenced in Section 1.69 of the CFTC 

Regulations), other than a direct or indirect equity or other interest in Refinitiv US LLC, that 

could reasonably be expected to be affected by the action. A direct and substantial financial 
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interest includes positions in Contracts in accounts of, controlled by, or affiliated with the 

Interested Person or in any other types of direct and substantial financial positions of the 

Interested Person that are reasonably expected to be affected by the deliberations or vote; 

and/or

(6) any other circumstance that gives rise to a conflict between the Director’s, Officer’s, Disciplinary 

Panel Member’s or Other Person’s exercise of authority concerning any Self-Regulatory Action 

and his or her personal interests.

c) Before considering any Self-Regulatory Action, an Interested Person must disclose in writing to the 

Board the material facts concerning his or her relationship or interest in the matter.

d) Any Interested Person who would be required otherwise to abstain from deliberations and voting 

pursuant to Rule 210(a) as a result of having a direct and substantial financial interest in the result of 

the deliberations and vote may participate in deliberations, but shall not vote on the matter, if:

(1) the material facts about the Interested Person’s financial interest in the matter are disclosed or 

known to the Board, Committee, or Disciplinary Panel;

(2) the Board, Committee, or Disciplinary Panel determines that the participation by the Interested 

Person would be consistent with the public interest; and

(3) a majority of the Directors (excluding any Interested Persons) vote to allow the Interested 

Person to participate in deliberations on the matter.

e) If a determination is made pursuant to Rule 210(d) that an Interested Person may participate in 

deliberations prior to a vote, then the minutes of the meeting of the Board or committee thereof will 

reflect the determination and the reasons for the determination.

f) If a determination is made that all Directors are Interested Persons with respect to a matter subject to a 

vote by the Board, the Chief Executive Officer will appoint a panel of individuals who are not Interested 

Persons with respect to such matter, which will have the same authority and powers over such matter 

that the Board would have if the Directors were not Interested Persons with respect to such matter.

g) No Director, Officer or member of any committee or panel established by the Board shall use or 

disclose for any purpose other than the performance of his or her official duties and responsibilities as 

a Director, Officer or committee or panel member any material, non-public information obtained as a 

result of the individual’s duties and responsibilities as a Director, Officer or committee or panel 

member. No Director, Officer or committee or panel member shall, directly or indirectly, disclose or use 

at any time, either during his or her association with the SEF or thereafter, any confidential information 

of which the Board member or committee or panel member becomes aware. Each Director, Officer or 

committee or panel member in possession of confidential information shall take all appropriate steps to 

safeguard the information and to protect it against disclosure, misuse, espionage, loss and theft.

h) Notwithstanding Rule 210(g), a Director, Officer or committee or panel member may disclose 

confidential information if required by Applicable Law or a court order to be revealed to the United 

States Department of Justice or the CFTC.

i) For the purposes of Rule 210(g), the terms “material information” and “non-public information” shall 

each have the meaning set forth in CFTC Regulation § 1.59(a) or any successor regulation.

RULE 211 INFORMATION-SHARING AGREEMENTS

a) The SEF may enter into information-sharing agreements or other arrangements or procedures to 

coordinate surveillance with other markets on which financial instruments related to the Contracts 

trade, and such international information-sharing agreements as the CFTC may require. As part of any 

information-sharing agreements or other arrangements or procedures adopted pursuant to this Rule, 

the SEF may:
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(1) provide market surveillance reports to the CFTC, any Government Agency with jurisdiction over 

the SEF or, as necessary for the SEF to comply with its SRO obligations, to other markets;

(2) share information and documents concerning current and former Participants with the CFTC, 

any Government Agency with jurisdiction over the SEF or, as necessary for the SEF to comply 

with its SRO obligations, to other markets;

(3) share information and documents concerning ongoing and completed investigations with the 

CFTC, any Government Agency with jurisdiction over the SEF or, as necessary for the SEF to 

comply with its SRO obligations to other markets; and/or

(4) require its current or former Participants to provide information and documents to the SEF at the 

request of the CFTC, any Government Agency with jurisdiction over the SEF or, as necessary 

for the SEF to comply with its SRO obligations, other markets.

b) The SEF may enter into any information sharing arrangement with any Person or body (including, 

without limitation, the CFTC, the NFA, any Self-Regulatory Organization, any exchange, market, or 

Derivatives Clearing Organization, or foreign regulatory authority) if the SEF considers such 

arrangement to be in furtherance of the SEF’s purpose or duties under the SEF Rules or any law or 

regulation.

c) The SEF may disclose to any Person or entity information concerning or associated with a Participant 

or other Person that the SEF believes is necessary and appropriate in exercising a legal or regulatory 

function, whether or not a formal arrangement governing the disclosure exists or a request for 

information was made.

RULE 212 SERVICES AGREEMENT WITH A 

REGULATORY SERVICES PROVIDER

a) The SEF may choose to contract with a Regulatory Services Provider, for the provision of services to 

assist in complying with the core principles, as approved by the Commission. If the SEF chooses to 

contract with a Regulatory Services Provider, it will ensure that the Regulatory Services Provider has 

the capacity and resources necessary to provide timely and effective regulatory services, including 

adequate staff and automated surveillance systems.

b) If the SEF chooses to contract with a Regulatory Services Provider, the SEF will at all times remain 

responsible for the performance of any regulatory services received, for compliance with the SEF’s 

obligations under the CEA and Commission regulations, and for the Regulatory Services Provider’s 

performance on its behalf.

c) If the SEF chooses to contract with a Regulatory Services Provider, the SEF will retain exclusive 

authority in all substantive decisions made by its Regulatory Services Provider, including but not 

limited to decisions involving the cancellation of trades, the issuance of disciplinary charges against 

Participants or market participants, and denials of access to the trading platform for disciplinary 

reasons. The SEF shall document any instances where its actions differ from those recommended by 

its Regulatory Services Provider, including the reasons for the course of action recommended by the 

Regulatory Service Provider and the reasons why the SEF chose a different course of action.

RULE 213 SERVICES AGREEMENT WITH A 

TECHNOLOGY SERVICES PROVIDER

a) The SEF may contract with a Technology Services Provider to provide certain technology services to 

the SEF pursuant to a Technology Services Agreement. In accordance with a Technology Services 
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Agreement, a Technology Services Provider may perform certain functions under the SEF Rules and 

the SEF may provide information to the Technology Services Provider in connection with the 

performance by the Technology Services Provider of those functions.

b) The SEF shall retain ultimate decision-making authority with respect to any functions that are 

contracted to a Technology Services Provider.
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Chapter 3 Participants

RULE 301 CRITERIA FOR BECOMING A PARTICIPANT

a) To be eligible for admission as a Participant of the SEF, an applicant must demonstrate to the 

satisfaction of the SEF that it:

(1) is an Eligible Contract Participant (which may be demonstrated through a representation);

(2) is of good reputation and business integrity;

(3) maintains adequate financial resources and credit;

(4) is of the age of majority in the individual’s state of residence (if an individual);

(5) is validly organized, in good standing, and authorized by its governing body and, if relevant, 

documents of organization, to trade Contracts (if an entity);

(6) has not filed for bankruptcy;

(7) is not prohibited from using the services of the SEF for any reason whatsoever;

(8) holds all registrations required under Applicable Law, including any Swap Dealer, Major Swap 

Participant, Introducing Broker, Futures Commission Merchant, commodity pool operator, 

commodity trading advisor, associated person registration, as applicable;

(9) is not subject to statutory disqualification under Section 8a(2) of the CEA;

(10) consents to the SEF’s jurisdiction pursuant to Rule 311; and

(11) satisfies any other criteria that the SEF may require from a Participant.

If a Participant’s status as an Eligible Contract Participant changes, such Participant must immediately 

notify the SEF of such change.

b) No Participant, including a Participant that is an Account Manager or a Sponsoring Participant, shall 

carry an account for a Customer, enter an Order in the name of or on behalf of a Client or extend 

Trading Privileges to a Sponsored Person unless the Participant has entered into a written 

Intermediary Agreement with such Customer, Client or Sponsored Person, that is in compliance with 

Applicable Law and the SEF Rules and Obligations.

c) Each Participant must: (1) ensure that the Customer, Client or Sponsored Person is an Eligible 

Contract Participant at the time of execution of any Swap; (2) subject every Swap executed for the 

Customer, Client or Sponsored Person to the SEF Rules and Obligations insofar as they are 

applicable to that Swap; (3) in relation to any Swap executed for the Customer, Client or Sponsored 

Person, be able to comply with all requirements of the SEF Rules and Obligations and any other 

arrangements, provisions and directions given by the SEF; and (4) provide the SEF and its agents, 

including the Regulatory Services Provider, access to all information and staff in connection with or 

related to its SEF Activity necessary for monitoring and enforcement of the SEF Rules and Obligations.

d) Once admitted, the Participant shall continue to comply with all applicable eligibility criteria in Rule 

301(a).

e) [Reserved]

f) [Reserved]

g) [Reserved]

h) [Reserved]
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i) [Reserved]

j) The SEF may allow, deny, suspend, or permanently bar a Participant’s access to the Platform 

pursuant to disciplinary measures or emergency action, or for any other reason at the sole discretion of 

the SEF or its Regulatory Service Provider, provided that any decision to allow, deny, suspend, or 

permanently bar a Participant’s access to the Platform shall be impartially enforced.

RULE 302 PARTICIPANT APPLICATION PROCESS

a) Any Person who desires to become a Participant shall:

(1) enter into a User Agreement or Swap Execution Facility Addendum;

(2) [Reserved]

(3) [Reserved]

(4) agree to abide by the SEF Rules and Applicable Law;

(5) provide such information and documentation as may be requested by the SEF pertaining to the 

Participant or the Participant’s Clients if Participant is an Account Manager, and follow the 

procedures established by the SEF for admission; and,

(6) if Participant is organized or located outside of the United States, enter into a written agreement 

acceptable to the SEF appointing a third party as its U.S. agent for service of process for 

purposes of CFTC Regulation 15.05, and shall provide the SEF with a copy of the agreement.

b) In considering an application from a potential Participant, the SEF may require additional information 

from the applicant, or conduct an investigation to verify information submitted by the applicant, or both.

c) In determining whether to admit an applicant as a Participant, the SEF will evaluate, among other 

things, the applicant’s disciplinary history and financial and operational soundness.

d) If the SEF decides to admit an applicant as a Participant, it shall promptly notify the applicant and state 

in such notice the date on which the applicant shall become a Participant.

e) The SEF may deny, condition, or terminate Participant status of any Person:

(1) If such Person is unable to satisfactorily demonstrate its ability to satisfy the eligibility criteria to 

become or remain a Participant;

(2) If such Person is unable to satisfactorily demonstrate its capacity to adhere to all applicable SEF 

Rules;

(3) If such Person would bring the SEF into disrepute as determined by the SEF in its sole 

discretion; or,

(4) for such other cause as the SEF may reasonably determine provided that any decision to deny, 

condition or terminate the Participant status of any Person shall be impartially enforced.

f) If the SEF has a Regulatory Service Provider pursuant to Rule 212, the SEF shall nonetheless retain 

exclusive authority over decisions to deny access to the SEF.

g) If the SEF decides to decline or condition an application for admission as a Participant, or terminate a 

Person’s status as a Participant, the SEF shall promptly notify such Person (the “Affected Person”) 

thereof in a writing sent to the address provided by the applicant in the SEF Participant Application 

form or maintained in the SEF registry of Participants. Such Affected Person may, within seven (7) 

calendar days, request in writing that the SEF provide the reasons for the denial, conditioning or 

termination of Participant status. Within fourteen (14) calendar days after receiving such written 

request, the SEF shall send a written response to the Affected Person setting forth the reasons for the 
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denial, conditioning or termination. Within fourteen (14) calendar days of receiving the SEF’s written 

response, the Affected Person may request in writing that the Board reconsider the determination.

h) Within twenty-eight (28) calendar days of receiving any request for reconsideration, the Board shall 

either confirm, reverse or modify the denial, conditioning or termination of the Affected Person as a 

Participant, and shall promptly notify the Affected Person accordingly in writing. The Board may, within 

its discretion, schedule a hearing (in-person or by teleconference); request additional information from 

the Affected Person; or, establish any other process that it believes is necessary and appropriate to 

consider the request for reconsideration.

i) The Board’s decision is the final action of the SEF and is not subject to appeal within the SEF.

j) Access to the SEF by an ISV shall be provided in a fair and nondiscriminatory manner, but a Person 

seeking to act as an ISV must:

(1) execute the ISV Agreement,

(2) satisfy the SEF’s technological integrity requirements and not adversely affect the SEF’s ability 

to comply with the CEA and CFTC Regulations,

(3) agree to the terms of the ISV Agreement (including all applicable annexes and exhibits), the 

SEF Rules and any and all other documents referenced in the ISV Agreement, and

(4) provide all information that may be reasonably requested from time to time by the SEF.

k) Persons seeking access to the Platform via an ISV must themselves be Participants or Clients or 

Customers of a Participant.

RULE 303 TRADING PRIVILEGES

a) A Participant must execute such Participant Documentation as required from time to time by the SEF, 

and such Participant Documentation must remain in effect for the Participant to maintain its Trading 

Privileges.

b) Admission as a Participant only entitles the Participant to the Trading Privileges and does not confer 

any right of ownership in, or right to attend or vote at meetings of, the SEF, or right to share in the 

profits, of the SEF. A Participant may not transfer or assign its status as a Participant without the prior 

written consent of the SEF, and any purported transfer or assignment without the SEF’s prior consent 

is not binding on the SEF.

c) Any Person that has been granted Trading Privileges, including a Sponsored Person, is a member of 

the SEF for purposes of the CEA.

RULE 304 ACCESS TO THE PLATFORM

a) The SEF may at any time revoke, suspend, limit, condition, restrict or qualify a Participant’s or 

Sponsored Person’s Trading Privileges and/or ability to access the Platform, if in the sole discretion of 

the SEF or its Regulatory Service Provider, such action is in the best interests of the SEF, provided 

that any decision to revoke, suspend, limit, condition, restrict or qualify a Participant’s or Sponsored 

Person’s Trading Privileges and/or ability to access the Platform shall be impartially enforced.

b) [Reserved]
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RULE 305 DUES, ASSESSMENTS AND FEES

a) The SEF shall have the authority to set the amounts and times of payment for any dues, assessments 

or fees to be paid by Participants. These dues, assessments or fees may include, but not be limited to, 

the Platform fees, clearing fees, brokerage fees, transaction surcharges, and the fees described in 

Rules 401(a)(5) and 402(a)(7).

b) Each Participant agrees to pay such dues, assessments, and fees as are published by the SEF from 

time to time. Each Participant agrees to pay such dues, assessments, and fees when due.

c) If a Participant fails to pay when due any such dues, assessments or fees levied on such Participant, 

and such payment obligation remains unsatisfied for thirty (30) days after its due date, the SEF may 

suspend, revoke, limit, condition, restrict or qualify the Participant’s Trading Privileges and/or ability to 

otherwise access the Platform as it deems necessary or appropriate.

d) The SEF may modify or amend such dues, assessments, or fees as are published by the SEF through 

a Notice to Participants as described in Rule 309, and any such amendment shall be applicable to and 

binding on the Participant and shall be effective twenty-five (25) calendar days after the later of the 

date that it is posted on the SEF website and is transmitted to Participants; provided, however, that 

notwithstanding any provision in the User Agreement, a Participant may terminate its membership in 

the SEF by providing written notice to the SEF that it objects to a modification or amendment of the 

SEF’s dues, assessments or fees within thirty (30) calendar days of the effective date of any such 

modification or amendment. Any termination under this Rule 305(d) will become effective fifteen (15) 

calendar days after such written notice is received by the SEF. Any Participant that terminates its 

membership under this Rule 305(d) shall remain responsible for any dues, assessments, fees and 

Obligations applicable to any Transactions effected or activity conducted prior to any such termination, 

and Rule 931 shall survive any such termination.

RULE 306 PARTICIPANT REPRESENTATIVES

Rule 306.A Authorized Persons

a) Each Participant who is not a natural person shall designate an Authorized Person(s) by listing such 

Authorized Persons on the SEF Participant Application or by otherwise providing the SEF with the 

information requested in the SEF Participant Application related to Authorized Persons. Participant 

must designate an Authorized Person prior to permitting such Authorized Person to access the 

Platform and agrees to notify the SEF of any change in its Authorized Persons.

b) Any person who is an Authorized Person must: (i) utilize the Participant’s Legal Entity Identifier for all 

activities on the Platform; and (ii) utilize the User ID provided by the SEF to such Authorized Person.

Rule 306.B Authorized Representatives

a) Authorized Representatives will represent the Participant before the SEF and its committees and 

receive notices on behalf of such Participant.

b) Authorized Representatives shall be empowered by the Participant to act on its behalf, and the SEF 

shall be entitled to rely on the actions of Authorized Representatives as binding on the Participant, 

unless and until Participant has notified the SEF that such Authorized Representative's designation 

has been revoked

c) Each Participant must provide the SEF with current contact and other requested information for each 

of its Authorized Representatives so that the SEF is able to immediately contact such Authorized 

Representatives.
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RULE 307 IDENTIFICATION OF AUTHORIZED 

PERSONS

a) Each person trading on behalf of a Participant or a Sponsored Person shall be identified to the SEF by 

Participant’s or Sponsored Person’s Legal Entity Identifier and shall be subject to the SEF Rules. It is 

the duty of the Participant and Sponsored Person to ensure that Legal Entity Identifiers are current and 

accurate at all times. If a Participant or Sponsored Person’s Legal Entity Identifier is changed for any 

reason and at any time, such Participant or Sponsored Person (as the case may be) must inform the 

SEF via its relationship manager within three (3) Business Days of such amendment. Participant and 

Sponsored Persons shall not use, and the SEF may deny Participant access to, the Platform at any 

time that Participant has, or is required by CFTC regulations to have, a Legal Entity Identifier if 

Participant does not have such a Legal Entity Identifier, as the case may be, or has not notified the 

SEF in writing of such Legal Entity Identifier.

b) Each Participant and each Authorized Person will also individually receive a User ID and a 

corresponding password to enable such Participant or Authorized Person to access and use the 

Platform. Each individual must use a Legal Entity Identifier and User ID to access the Platform. In no 

event may a Person enter an Order or permit the entry of an Order by an individual using User ID other 

than the individual’s own User ID.

c) Upon becoming aware of any improper access to or use of the Platform, Participant shall immediately 

notify the SEF and shall immediately terminate such Person’s access to and use of the Platform. 

Participant shall be responsible for, and shall take and maintain appropriate steps to ensure, the 

security of Participant’s (and Participant’s Authorized Persons’) use of the Platform.

RULE 308 RECORDING OF COMMUNICATIONS

The SEF or the Regulatory Services Provider may record conversations and retain copies of electronic 

communications between SEF Officials, on one hand, and Participants and their Authorized Persons, on 

the other hand. Any such recordings may be retained by the SEF or the Regulatory Services Provider in 

such manner and for such periods of time as the SEF may deem necessary or appropriate. The SEF or 

Regulatory Services Provider will retain such recording in compliance with CFTC Regulations. The 

Regulatory Services Provider will have access to such recordings to the extent required to perform certain 

regulatory services to the SEF pursuant to the Regulatory Services Agreement. Participants hereby 

consent to such recordings.

RULE 309 NOTICES TO PARTICIPANTS

a) The SEF shall publish and transmit a Notice to Participants with respect to each addition to, 

modification of, or clarification of, the SEF Rules or of any action to implement any of the SEF Rules. A 

Notice to Participants shall be posted on the SEF’s website and transmitted to Participants via an 

electronic mail distribution or through any other electronic or digital communications system not 

prohibited by Applicable Law in order to enable each Participant to become aware of and familiar with, 

and to implement any necessary preparatory measures to be taken by it with respect to, such addition 

or modification, prior to the effective date thereof.

b) Any Notice to Participants published and transmitted in accordance with Rule 309(a) shall also be 

deemed to have been made to all Account Managers, Clients, Customers, Sponsored Persons, 

Authorized Representatives and Authorized Persons.
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RULE 310 COMMUNICATIONS BETWEEN THE SEF 

AND PARTICIPANTS

a) Each Participant must provide the SEF with its current electronic mail address and telephone number 

and the electronic mail address and telephone number of any of its Authorized Persons, and 

immediately (and in any event within 24 hours) update this information whenever it changes.

b) All communications made to Participants shall also be deemed to have been made to all Authorized 

Representatives and Authorized Persons, and all communications made to an Authorized 

Representative or Authorized Person shall also be deemed to have been made to Participant.

RULE 311 APPLICATION OF THE SEF RULES AND 

JURISDICTION

a) By becoming a Participant, accessing the Platform or entering any Order or submitting any Contract 

into the Platform, whether directly or through an intermediary, and without any need for any further 

action, undertaking or agreement, a Participant and its Authorized Person(s), and the Clients and 

Customers of any Participant, and any Sponsored Person, any ISVagree:

(1) to be bound by, and comply with, the SEF Rules and obligations and Applicable Law, in each 

case to the extent applicable to it;

(2) to become subject to the jurisdiction of the SEF with respect to any and all matters arising from, 

related to, or in connection with, the status, actions or omissions of such Person;

(3) to permit the SEF and any Regulatory Services Provider authorized to act on behalf of the SEF 

to access any and all information relevant to activities related to the SEF business;

(4) to assist the SEF in complying with its legal and regulatory obligations, cooperate with the SEF 

and the CFTC in any inquiry, investigation, audit, examination or proceeding; and

(5) that the SEF is authorized to provide information regarding such Person to the Regulatory 

Services Provider, the CFTC or any Self-Regulatory Organization.

b) Any Participant, its Authorized Person(s), and the Clients and Customers of any Participant, or any ISV 

whose Trading Privileges and/or ability otherwise to access the Platform are revoked or terminated 

shall remain bound by the SEF Rules and Applicable Law, in each case to the extent applicable to it, 

and subject to the jurisdiction of the SEF with respect to any and all matters arising from, related to, or 

in connection with, the status, actions or omissions of such Person prior to such revocation or 

termination.

RULE 312 DESCRIPTION OF PARTICIPANT’S STATUS

A Participant shall ensure that the form, content and context of any description of the Participant’s status on 

the SEF to Customers is not inconsistent with, and does not misrepresent, the Participant’s capacity on the 

SEF under the SEF Rules or the Participant’s registration, if any, under the CEA, or under any other 

Applicable Law.
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RULE 313 DEATH OR DISSOLUTION OF A 

PARTICIPANT 

All rights and privileges of a Participant terminate upon, and all obligations of a Participant shall survive, the 

death or incapacity of the Participant (if an individual) or the dissolution of the Participant (if an entity).

RULE 314 WITHDRAWAL OF PARTICIPANT

a) To withdraw from the SEF, a Participant must notify the SEF following the procedures established by 

the SEF. Except as otherwise required by law or regulation or by request or order of a Government 

Agency, such withdrawal will be effective immediately upon receipt of the withdrawal by the SEF.

b) Upon the effectiveness of the withdrawal of a Participant, all rights and privileges of such Participant 

terminate (including, without limitation, the Trading Privileges and ability to access the Platform) 

immediately. The SEF may suspend Trading Privileges prior to termination if necessary to 

appropriately effectuate termination. The accepted withdrawal of a Participant shall not affect the rights 

of the SEF under the SEF Rules or relieve the former Participant of its Obligations under the SEF 

Rules, to perform all contracts involving any Contracts entered into by such, or to pay any the SEF 

fees, costs, or charges incurred, before the withdrawal. Notwithstanding the accepted withdrawal of a 

Participant, the withdrawn Participant remains subject to the SEF Rules, the Obligations and the 

jurisdiction of the SEF for acts done and omissions made while a Participant, and must cooperate in 

any SEF Proceeding under Chapter 10 as if the withdrawn Participant were still a Participant.

RULE 315 COMPLIANCE WITH THE CEA

a) All Participants, all Clients and Customers of any Participant that is an Account Manager and all 

Sponsored Persons shall comply with the provisions of the CEA and CFTC Regulations, including the 

filing of reports, maintenance of books and records, and permitting inspection and visitation by duly 

authorized representatives of the CFTC or Department of Justice.

RULE 316 SPONSORED ACCESS

a) A Participant may be a Sponsoring Participant and may request that the SEF grant one or more 

Sponsored Person(s) Sponsored Access, pursuant to the terms and conditions of the SEF Rules. Each 

Sponsored Person shall designate one or more Authorized Persons to transact on the SEF.

b) Upon receipt of a request for the granting of Sponsored Access, the SEF will make a determination 

whether or not to grant such Sponsored Access. The SEF shall notify a Sponsoring Participant of its 

determination in writing. A Sponsoring Participant’s designation of a Sponsored Person for Sponsored 

Access shall be effective upon the approval of the SEF. The SEF will issue SEF User IDs for each 

Authorized Person of the Sponsored Person for which Sponsored Access is approved.

c) Prior to designating a Sponsored Person, the Sponsoring Participant shall submit or cause the 

Sponsored Person to submit information with respect to the Sponsored Person as required by the 

SEF, including information regarding the Sponsored Person’s Authorized Persons.

d) Sponsoring Participant Obligations. With respect to each Sponsored Person which it has designated 

for Sponsored Access to the SEF, and in respect of the applicable Transactions on the SEF, the 

Sponsoring Participant shall:
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(1) represent and warrant to the SEF that it has entered into an Intermediary Agreement with such 

Sponsored Person that satisfies the requirements set forth in Rule 301(b) and which obligates 

such Sponsored Person to: (i) assist the SEF in complying with its legal and regulatory 

obligations, cooperate with the SEF and the CFTC in any inquiry, investigation, audit, 

examination or proceeding and (ii) acknowledge that the SEF is authorized to provide 

information regarding such Sponsored Person to the Regulatory Services Provider, the CFTC or 

any Self-Regulatory Organization;

(2) be responsible for all Orders and Transactions placed by any Person acting on behalf of or in 

the name of the Sponsored Person on the SEF as if such Orders and/or Transactions were 

placed by the Sponsoring Participant (whether or not the Sponsoring Participant was aware of 

and/or had approved the placing of such Orders or Transactions). Any execution occurring as a 

result of an Order entered by a Sponsored Person shall be binding in all respects on the 

Sponsoring Participant;

(3) assist the SEF in any investigation into actual or potential violations of the SEF Rules which 

occur through or with respect to the activity of each Sponsored Person. Such assistance must 

be timely and may include but not be limited to, requiring the Sponsored Person to produce 

documents, to answer questions from the SEF, and/or appear in connection with an 

investigation:

(4) suspend or terminate the Trading Privileges of a Sponsored Person or any Authorized Trader 

associated with such

(5) Sponsored Person if the SEF determines that the actions of the Sponsored Person or any of its 

Authorized Persons threaten the integrity of the SEF or liquidity of any Swap, or violate any SEF 

Rule, or if the Sponsored Person or any of its Authorized Persons fails to cooperate in an 

investigation.

e) If a Sponsoring Participant has actual or constructive notice of a violation of the SEF Rules in 

connection with the Sponsored Access by its Sponsored Person and the Sponsoring Participant fails to 

take appropriate action, the SEF may consider that the Sponsoring Participant has committed an act 

detrimental to the interest or welfare of the SEF in violation of Rule 912.

f) The SEF may, in its sole discretion, revoke, suspend, limit, condition, restrict or qualify the designation 

of a Sponsored Person, and shall notify the Sponsoring Participant of such action in accordance with 

SEF procedures, provided that any decision to revoke, suspend, limit, condition, restrict or qualify the 

designation of a Sponsored Person shall be impartially enforced.

g) A Sponsoring Participant that seeks to terminate the designation of a Sponsored Person shall notify 

the SEF in writing, providing such information as the SEF may require. Except as otherwise required 

by law or regulation or by request or order of a Government Agency, such termination will be effective 

immediately upon receipt of the notification from the Sponsoring Participant by the SEF.

h) Upon the effectiveness of the termination of a Sponsored Person, all rights and privileges of such 

Sponsored Person terminate (including, without limitation, the Trading Privileges and ability to access 

the Platform) immediately. The SEF may suspend Trading Privileges prior to termination if necessary 

to appropriately effectuate termination. The termination of a Sponsored Person shall not affect the 

rights of the SEF under the SEF Rules or relieve the former Sponsored Person of its Obligations under 

the SEF Rules or to perform all contracts involving any Contracts entered into by such Sponsored 

Person, before the termination. Notwithstanding the termination of a Sponsored Person, the terminated 

Sponsored Person remains subject to the SEF Rules, the Obligations and the jurisdiction of the SEF 

for acts done and omissions made while a Sponsored Person, and must cooperate in any SEF 

Proceeding under Chapter 10 as if the terminated Sponsored Person were still a Sponsored Person.
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RULE 401 REAL-TIME PUBLIC REPORTING

a) In General.

(1) CFTC Regulation Part 43, which sets forth the rules regarding real-time reporting, requires 

certain transaction data to be reported to a Swap Data Repository as soon as technologically 

practicable after Execution.

(2) The responsibilities for real-time reporting pursuant to CFTC Regulation Part 43 will vary 

depending on whether or not the Transaction is executed on or pursuant to the SEF Rules.

(3) A Participant or Participant’s Counterparty must transmit all data required to be reported under 

CFTC Regulation Part 43 for any Block Trades to the SEF as soon as technologically 

practicable after Execution, but in any event no later than 10 minutes after Execution.

(4) For all Transactions executed on the Platform or pursuant to the SEF Rules, including Block 

Trades, the SEF will fulfill the real-time reporting obligations in CFTC Regulation Part 43 by 

reporting transaction and pricing data to the DTCC, including an actual description of the 

underlying assets. The SEF may enter into contractual relationships with third party service 

providers to transmit the Swap transaction and pricing data to a Swap Data Repository.

(5) The SEF shall have the authority to charge fees for the transmission of transaction and pricing 

data to a real-time disseminator for Transactions executed on the Platform or pursuant to the 

rules of the SEF; provided, however, that such fees shall be equitable and non-discriminatory.

b) Pursuant to CFTC Regulation § 43.3(b), or any successor regulation thereto, and consistent with 

CFTC Regulation Part 43 and Appendix A to Part 43, the SEF will report all transaction and pricing 

data for Transactions executed on the Platform or pursuant to the SEF Rules as soon as 

technologically practicable after Execution to a registered Swap Data Repository for public 

dissemination.

c) Pursuant to CFTC Regulation § 43.4(f)(2), or any successor regulation thereto, the SEF will report the 

actual notional or principal amount for all Swaps executed on or pursuant to the rules of the SEF, 

including those of any Block Trade, to a registered Swap Data Repository. However, this amount may 

be rounded or capped by such Swap Data Repository prior to public dissemination.

d) The SEF will not disclose transaction or pricing data for any Transactions to the general public prior to 

the public dissemination of such data. However, the SEF may transmit such data on a nondiscriminatory basis to Participants and any market participants subscribing to the SEF for information 

services after or at the same time that the SEF transmits such data to a registered Swap Data 

Repository pursuant to Rule 401(b).

e) Real-time dissemination of Block Trades will be done in accordance with Rule 602.

RULE 402 REGULATORY REPORTING

a) Reporting Creation Data.

(1) CFTC Regulation Part 45, which sets forth the rules regarding regulatory reporting, requires 

Creation Data for any Transaction to be reported to a single Swap Data Repository after 

Execution. Creation Data includes the Primary Economic Terms and Confirmation Data.
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(2) The responsibilities for regulatory reporting pursuant to CFTC Regulation § 45.3, or any 

successor regulation thereto, will vary depending on whether or not the Transaction is executed 

on or pursuant to the SEF Rules and whether or not the Transaction is cleared.

(3) A Participant or Participant’s Counterparty must transmit all data required to be reported under 

CFTC Regulation Part 45 for any Block Trades to the SEF as soon as technologically 

practicable after Execution.

(4) The Counterparty that is the Reporting Counterparty will be determined pursuant to CTFC 

Regulation § 45.8.

i. In the following types of Transactions, the seller of risk in the currency which is first, when 

sorted alphabetically by ISO code, shall be the Reporting Counterparty:

1. Both Counterparties are Swap Dealers, or both Counterparties are Major Swap 

Participants, or both Counterparties are neither Swap Dealers nor Major Swap 

Participants that are financial entities as defined in CEA section 2(h)(7)(C), or 

both Counterparties are neither Swap Dealers nor Major Swap Participants and 

neither Counterparty is a financial entity as defined in CEA section 2(h)(7)(C).

2. Neither Counterparty is a Swap Dealer or Major Swap Participant, and neither 

Counterparty is a U.S. Person.

ii. For non-deliverable swaps, Rule of 402(a)(4)(i) (if applicable) will be applied to the far leg 

of the swap to determine the Reporting Counterparty.

iii. For FX Options, in the types of transactions set forth in Rule 402(a)(4)(i) or (ii), the 

Reporting Counterparty shall be the seller of the Option.

(5) For all Transactions executed on the Platform or pursuant to the SEF Rules, including Block 

Trades, the SEF will report the Primary Economic Terms and Confirmation Data to the DTCC. 

The SEF may enter into contractual relationships with third party service providers to transmit 

the Primary Economic Terms and Confirmation Data to such Swap Data Repository.

i. The SEF relies upon CFTC No-Action Letter 17-17, titled “Extension of No-Action Relief 

for Swap Execution Facility Confirmation and Recordkeeping Requirements under 

Commodity Futures Trading Commission Regulations 37.6(b), 37.1000, 37.1001, 45.2, 

and 45.3(a)” in reporting Confirmation Data to the DTCC. This No-Action Letter will expire 

on the effective date of revised CFTC Regulations that amend the CFTC’s requirements 

regarding SEF confirmations.

(6) Participant must provide the SEF with sufficient information to enable the SEF to report all 

Creation Data, including without limitation:

i. The Legal Entity Identifier or CICI of the Participant;

ii. A yes/no indication of whether Participant is a Swap Dealer with respect to the product 

with respect to which the Order is placed;

iii. A yes/no indication of whether Participant is a Major Swap Participant with respect to the 

product with respect to which the Order is placed.

iv. A yes/no indication of whether Participant is a financial entity as defined in CEA section 

(2)(h)(7)(C);

v. A yes/no indication of whether Participant is a U.S. Person;

vi. If applicable, an indication that Participant will elect the End-User Exception for any Swap 

resulting from the order;

vii. If the Transaction will be allocated:

1. An indication that the Transaction will be allocated.
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2. The Legal Entity Identifier or CICI of the agent.

3. An indication of whether the Swap is a post-allocation swap.

4. If the swap is a post-allocation swap, the Unique Swap Identifier of the original 

Transaction between the Reporting Counterparty and the agent.

(7) The SEF shall have the authority to charge fees for any services provided pursuant to this Rule 

402; provided, however, that such fees shall be equitable and non-discriminatory.

b) Reporting Continuation Data.

(1) CFTC Regulation Part 45 requires Continuation Data to be reported to the same Swap Data 

Repository referenced in Rule 401(a)(1) during the life of any Transaction. Continuation Data 

includes life-cycle event data or state data, each as defined in CFTC Regulation § 45.1, or any 

successor regulation thereto, and Valuation Data.

(2) [Reserved]

(3) Pursuant to CFTC Regulation § 45.4(c), Continuation Data for any uncleared Transaction, 

whether or not the Transaction is executed on a Swap Execution Facility, will be reported to the 

relevant Swap Data Repository by the Reporting Counterparty.

(4) The SEF will have no obligation to fulfill any requirements to report Continuation Data for any 

Participant, including Valuation Data.

(5) If the SEF fulfills any requirements to report Continuation Data for any Participant that is a 

Reporting Counterparty, such Participant will at all times remain responsible for the performance 

of any and all regulatory reporting requirements imposed on such Participant under CFTC 

Regulation Part 45.

RULE 403 MAINTENANCE OF BOOKS AND RECORDS 

BY THE SEF

a) The SEF shall keep, or cause to be kept, full, complete and systematic records, together with all 

pertinent data and memoranda, of all activities relating to the business of the SEF with respect to 

Swaps. Such records shall include, without limitation, timestamps required to be maintained under 

CFTC Regulation § 43.3, a complete audit trail for all Swaps executed on or subject to the rules of the 

SEF, investigatory files, disciplinary files, all books and records required to be maintained pursuant to 

the CEA and CFTC Regulations, including CFTC Regulation Part 37. The SEF shall retain all such 

books and records, including, without limitation, a record of each Transaction executed on the 

Platform, in electronic form for at least five (5) years.

b) All records relating to Swaps, as described in Rule 403(a) above and pursuant to CFTC Regulation § 

45.2, shall be kept throughout the life of the Swap and for at least five (5) years following the final 

termination of the Swap. Records relating to Swaps shall be readily accessible via real time electronic 

access by the SEF throughout the life of the Swap and for two (2) years following the final termination 

of the Swap, and shall be retrievable by the SEF within three (3) business days through the remainder

of the period following final termination of the Swap during which it is required to be kept, pursuant to 

CFTC Regulation § 45.2(e)(1). As required by CFTC Regulation §§ 1.31 and 45.2(h), all books and 

records kept pursuant to this Rule 403, including audit trail data and reconstructions, shall be made 

available to the CFTC in a form, manner and time that is acceptable to the CFTC, and shall be open to 

inspection and examination by the CFTC, the Department of Justice, the Securities and Exchange 

Commission, and by any other regulator as authorized by the CFTC. Copies of all such records shall 

be provided, at the expense of the SEF, to the CFTC upon request, by electronic means, in hard copy, 

or both, as requested by the CFTC, except that copies of records originally created and exclusively 

maintained in paper form may be provided in hard copy only.
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c) The SEF shall include the Unique Swap Identifier for a swap in all of its records and all of its swap data 

reporting concerning that Swap, from the time it creates or receives the Unique Swap Identifier, 

throughout the existence of the Swap and for as long as any records are required by the CEA or CFTC 

Regulations to be kept by the SEF concerning the Swap, regardless of any life cycle events or any 

changes to state data concerning the Swap, including, without limitation, any changes with respect to 

the Counterparties to or the ownership of the Swap.

d) The SEF shall use the Legal Entity Identifier for each Counterparty in all of its records and all of its 

swap data reporting pursuant to CFTC Regulation Part 45.

e) The SEF shall use the Unique Product Identifier according to the system designated by the 

Commission, or if no such system has been designated, the internal product identifier or product 

description used by the Swap Data Repository to which a Swap is reported, in all of its records and all 

of its swap data reporting pursuant to CFTC Regulation Part 45.

RULE 404 TRANSACTION CONFIRMATIONS

a) The SEF will confirm each Transaction at the same time as Execution of the Transaction. The 

economic terms specific to the Transaction agreed to by the Participants on the SEF shall be reflected 

by the SEF in a written communication containing all of the terms of the Transaction (the “Trade 

Communication”) sent to the applicable Participants, which shall notify Participants that a Transaction 

has been executed.

(1) The Trade Communication, together with the previously-negotiated freestanding agreements 

between the counterparties (including, without limitation, ISDA master agreements, other master 

agreements, terms supplements, master confirmation agreements, and incorporated industry 

definitions) governing such Transaction existing at the time of such commitment to which the 

applicable Participants are party and which are incorporated by reference in the Trade 

Communication (the “Terms Incorporated by Reference”) shall, taken together, comprise all of 

the terms of such Transaction and constitute a confirmation for purposes of CFTC Regulation § 

37.6(b) and shall be deemed to be the “SEF Confirmation”.

(2) In satisfaction of the obligations imposed on the SEF under CFTC Regulation § 37.6(b): (i) each 

Trade Communication is deemed to incorporate the Terms Incorporated by Reference set forth 

in this Rule 404, and (ii) the Trade Communication shall state that it incorporates by reference 

the Terms Incorporated by Reference.

(3) The Trade Communication shall legally supersede any contradictory terms in the Terms 

Incorporated by Reference. Therefore, in the event of any conflict between (x) the Trade 

Communication and (y) the Terms Incorporated by Reference, the Trade Communication shall 

prevail to the extent of any inconsistency. The Trade Communication shall state that it legally 

supersedes any contradictory terms in the Terms Incorporated by Reference.

(4) [Reserved]

b) A SEF Confirmation shall be deemed to be a binding and fully enforceable confirmation of the 

Transaction between such parties.

c) A SEF Confirmation shall be deemed to be fully, and mutually executed by the parties, “signed” and “in 

writing” for any and all purposes, and the resulting SEF Confirmation shall constitute the controlling 

confirmation with respect to the applicable Transaction.

d) Participant agrees not to contest the legally binding nature or enforceability of any Transaction entered 

into or negotiated on the Platform and further agrees not to contest or assert any defense to the 

validity or enforceability of any Transaction on the basis that such Transaction was executed or 

negotiated electronically or on the basis of any law requiring agreements to be in writing or to be 

signed by the parties. Participant hereby waives any and all right to assert any such claims.
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e) Participant agrees to use commercially reasonable efforts to promptly review all SEF Confirmations 

and to reconcile any data or other discrepancies.

RULE 405 AUDIT TRAIL PROGRAM

a) The SEF’s audit trail permits it to track customer orders from the time of receipt through fill, allocation, 

or other disposition, and includes both order and trade data. The audit trail program includes all 

original source documents and an electronic transaction history database. The electronic transaction 

history database includes a history of all indications of interest, requests for quotes, orders, and trades 

entered into the Platform, including all orders and trades, and order modifications and cancellations. 

An adequate transaction history database also includes:

(1) All data that is input into the trade entry or matching system for the transaction to match and 

clear;

(2) Customer type indicator code;

(3) Timing and sequencing data adequate to reconstruct trading; and

(4) Identification of each account to which fills are allocated.

b) The SEF will enforce its audit trail and recordkeeping requirements through at least annual reviews of 

all Participants to verify their compliance with the SEF’s audit trail and recordkeeping requirements. 

Such reviews will include, but are not limited to, reviews of randomly selected samples of front-end 

audit trail data for order routing systems; a review of the process by which user identifications are 

assigned and user identification records are maintained; a review of usage patterns associated with 

user identifications to monitor for violations of user identification rules; and reviews of account numbers 

and customer type indicator codes in trade records to test for accuracy and improper use.

c) The SEF’s audit trail enforcement program will identify Participants that have failed to maintain high 

levels of compliance with such requirements and will sanction Participants for deficiencies. Sanctions 

will not include more than one warning letter for the same violation of audit trail or recordkeeping 

requirements within a rolling twelve month period.

RULE 406 MONITORING OF TRADING AND TRADE 

PROCESSING

The SEF will monitor trading on the Platform in order to prevent manipulation, price distortion, and 

disruptions of the delivery or cash settlement process through surveillance, compliance, and disciplinary 

practices and procedures, including through the real- time monitoring of trading, and comprehensive trade

reconstruction.

RULE 407 PUBLICATION OF TRADING INFORMATION

The SEF will publish trading information as required by CEA Section 5h(f)(9) and Parts 16 and 37 of CFTC 

Regulations.
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RULE 501 DUTIES AND RESPONSIBILITIES OF 

PARTICIPANTS

a) Each Participant shall (and shall cause all of its Authorized Persons and Clients, Customers and/or 

Sponsored Persons, if applicable, to):

(1) use the Platform in a responsible manner and not for any improper purpose;

(2) use the Platform only to conduct SEF Activity;

(3) conduct all SEF Activity in a manner consistent with SEF Rules and Obligations;

(4) comply with all SEF Rules and Obligations and act in a manner consistent with each SEF Rule 

and Obligation;

(5) comply with all rules of the Regulatory Service Provider, if any, to the extent applicable to it, and 

act in a manner consistent with the rules of the Regulatory Service Provider, if any, to the extent 

applicable;

(6) observe high standards of integrity, market conduct, commercial honor, fair dealing, and just and 

equitable principles of trade while conducting or attempting to conduct any SEF Activity, or any 

aspect of any business connected with or concerning the SEF;

(7) not knowingly mislead or conceal any material fact or matter in any dealings or filings with the 

SEF or in response to any SEF Proceeding;

(8) employ practices to monitor and enforce compliance with risk limits; and

(9) keep, or cause to be kept, complete and accurate books and records, including, without 

limitation, all books and records of its SEF Activity and his or her activity in the underlying 

commodity and related derivatives markets, and all books and records required to be maintained 

pursuant to the CEA, the CFTC Regulations or the SEF Rules, for the period required by 

Applicable Law, and make such books and records available for inspection by a representative 

of the SEF, the Regulatory Service Provider, the CFTC, or the Department of Justice, as 

required under CFTC Regulation 1.31.

b) Each Participant shall:

(1) be financially responsible for all Orders and Transactions in Contracts effected by such 

Participant, and for any use of the Platform made by Participant, the Participant’s Authorized 

Persons, or any Person using the Participant’s User ID.

(2) be responsible for promptly informing the SEF of any material changes to the information 

provided to the SEF by the Participant pursuant to Rules 301 and 302.

RULE 502 REQUIRED DISCLOSURES TO THE SEF

a) Each Participant shall immediately notify the Market Regulation Department upon becoming aware of 

any of the following events, in each case, with respect to the Participant’s status which relates to or 

may affect its participation or conduct on the SEF:

(1) any material change to the contact information provided to the SEF;
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(2) any damage to, or failure or inadequacy of, the systems, facilities or equipment of the Participant 

to effect transactions pursuant to the SEF Rules or to timely perform the Participant’s financial 

obligations under or in connection with Contracts;

(3) any refusal of admission, or involuntary withdrawal of the Participant for membership in, any 

Self-Regulatory Organization, Contract Market or Derivatives Clearing Organization;

(4) any expulsion, suspension or fine in excess of $25,000, cease and desist order, denial of trading 

privileges, censure or other sanction or remedy (whether through an adverse determination, 

voluntary settlement or otherwise) imposed on the Participant by any Self- Regulatory 

Organization, Contract Market or Derivatives Clearing Organization registered with the CFTC or, 

with respect to SEF Activity, any relevant Government Agency;

(5) any indictment or conviction of, or any confession of guilt or plea of guilty or nolo contendere by, 

the Participant (or, if the Participant is an entity, by any of its principals or senior officers) for any 

felony or misdemeanor involving, arising from, or related to, the purchase or sale of any 

commodity, swap, Futures contract, Option, security, securities futures product or other financial 

instrument, or involving or arising from fraud or moral turpitude;

(6) the Participant becoming the subject of a petition for bankruptcy;

(7) the appointment of a receiver, trustee or administrator for the Participant;

(8) the presentment of a petition, or the passing of a resolution, for the winding-up of Participant;

(9) the commencement of proceedings for the dissolution of Participant; or

(10) the occurrence of an event of insolvency with respect to the Participant.

RULE 503 INSPECTIONS BY THE SEF

a) The SEF (or the Regulatory Services Provider or other authorized representative) shall have the right 

with such prior reasonable advance notice as is practicable under the circumstances, in connection 

with determining whether all SEF Rules and Obligations are being, will be, or have been complied with 

by the Participant, to:

(1) inspect systems, equipment and software operated by the Participant in connection with its SEF 

Activity, wherever located; and/or

(2) copy or reproduce any data to which the SEF has access under this Rule 503.

b) Such books and records, systems, equipment and software shall be made available to the SEF and 

the Regulatory Services Provider, and their respective authorized representatives, during regular 

business hours. The SEF and the Regulatory Services Provider and their respective authorized 

representatives agree to adhere to Participant’s reasonable physical access and security procedures.

c) The Market Regulation Department may require a Participant to furnish (periodically or on a particular 

occasion) information concerning the Participant’s SEF Activity. Such information includes but is not 

limited to, the Participant’s open trading positions or Contracts to which the Participant is a party.

d) The Market Regulation Department may examine (periodically or on a particular occasion) the books 

and records of any Participant or any Customer or Client of a Participant, or any Sponsored Person 

that relate to SEF Activity.

e) Each Participant shall provide the Regulatory Services Provider with the same access to their books 

and records and offices as they are required to provide the SEF under the SEF Rules and Applicable 

Law.

f) The SEF shall provide information in its possession to the CFTC or the Regulatory Services Provider 

upon request in a form and manner approved by the CFTC. The SEF shall also share information with 
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other regulatory organizations, data repositories, and reporting services as required by the CFTC or as 

otherwise necessary and appropriate to fulfill its self- regulatory and reporting responsibilities. 

Appropriate information-sharing agreements can be established with such entities or the CFTC can act 

in conjunction with the SEF to carry out such information sharing.

g) Without limiting anything in this Rule 503 or elsewhere in the SEF Rules, a Participant shall furnish the 

Terms Incorporated by Reference to the SEF upon request. Upon request from the CFTC, the SEF 

shall request from Participants the Terms Incorporated by Reference and furnish such documents to 

the CFTC as soon as they are available.

RULE 504 MINIMUM REQUIREMENTS FOR 

PARTICIPANTS

a) Each Participant shall comply with the provisions of Applicable Law, including but not limited to the 

rules and regulations of any Government Agency that are imposed on a Participant relating to 

minimum financial requirements (if applicable), reporting and recordkeeping requirements, and any 

mandatory clearing requirements.

b) [Reserved]

c) Each Participant who is a Swap Dealer or Major Swap Participant shall be responsible for compliance 

with any mandatory trading requirements under CEA Section 2(h)(8) and CFTC regulations 

thereunder.

d) For a Non-Cleared Swap executed on or subject to the rules of the SEF, each Participant party must 

have entered into an agreement governing the execution and settlement of the Swap with the 

prospective Counterparty to such Swap prior to placing any Order related to such Swap.

e) A copy of any notice or written report that a Participant is required to file with the CFTC pursuant to 

CFTC Regulation § 1.12, or any successor regulation thereto, shall be concurrently provided to the 

SEF.

f) A Participant who violates any CEA provision or CFTC Regulation referred to in this Rule 504 shall be 

deemed to have also violated this Rule 504.

RULE 505 RECORDKEEPING REQUIREMENTS

a) In General.

(1) Each Person granted Trading Privileges must maintain or cause to be maintained records for all 

books and records required to be maintained in accordance with Applicable Law, including 

CFTC Regulations 1.31 and 1.35, and SEF Rule 501(a)(9).

b) Bunched Orders and Orders Eligible for Post Execution Allocation.

(1) Bunched Orders must be allocated and recorded in accordance with CFTC Regulation § 

1.35(b)(5), or any successor regulation thereto, and the NFA’s Interpretative Notice related to 

Compliance Rule 2-10 or any successor regulations.

c) Records of Underlying Commodity Activity and Related Transactions.

(1) As required by CFTC Regulations §§ 1.31 and 37.404, each Participant, Customer, Client and 

Sponsored Person must keep records of its trading on the SEF, including records of its activity 

in the commodity underlying any Swap and trading on related derivatives markets and make 

such records available, upon request, to the SEF, the CFTC, and the Department of Justice.
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RULE 506 CONFIDENTIALITY OF FINANCIAL AND 

OTHER INFORMATION

All information and data obtained or received by the Market Regulation Department from inspections of 

accounting and other records, quarterly balance sheets and declarations or reports on financial condition 

will be treated as confidential by the SEF; however, this Rule 506 does not supplant Rules 210, 1003(c), 

1201(e), or any other requirement of Applicable Law.

RULE 507 AUTHORITY TO REPORT

Whenever the SEF learns that Participant has failed to file any notice or written report required by CFTC 

Regulation § 1.12, or any successor regulation thereto, the SEF will immediately report this failure to the 

CFTC. The SEF may impose such conditions or restrictions on the business and operations of Participant 

that has failed to file any such notice or written report as the SEF may deem necessary or appropriate for 

the protection of Customers, other Participants, or the SEF.

RULE 508 BROKERS AND ACCOUNT MANAGERS

a) No Participant acting as a broker or Account Manager shall carry an account for a Customer or enter 

an Order in the name of or on behalf of a Client unless the Participant has entered into a written 

agreement with the Customer or Client containing such terms as may from time to time be prescribed 

in these SEF Rules, including without limitation, those rules contained in SEF Rule 301(b).

b) No Participant shall engage in soliciting or accepting an Order for the Contract for a Participant, 

Customer or Client unless the Participant has entered into a written agreement with the Participant, 

Customer or Client obtaining such terms as may from time to time be prescribed in these SEF Rules.

RULE 509 TREATMENT OF CUSTOMER FUNDS AND 

SECURITIES

Each Participant that is required to be registered with any Government Agency, including the CFTC and the 

U.S. Securities and Exchange Commission or any Self-Regulatory Organization, shall comply with the 

provisions of Applicable Law, including but not limited to the rules and regulation such Government Agency 

imposes on a Participant relating to the treatment of Customer funds and the maintenance of books and 

records with respect thereto. Any Participant that violates any of the aforementioned Government Agency 

Regulations shall be deemed to have violated this Rule 509.

RULE 510 DISCLOSURE REQUIREMENTS; KNOW 

YOUR COUNTERPARTY REQUIREMENTS

a) Each Participant must comply with all disclosure requirements set forth in applicable CFTC 

Regulations and rules of the Regulatory Service Provider, if any. Any such disclosure may be 

combined with a disclosure regarding the existence of financial interests held by the Participant in the 

SEF or any other Swap Execution Facility.
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b) Participants that are Swap Dealers or Major Swap Participants shall verify that each potential 

Counterparty is an Eligible Contract Participant with respect to each Swap as provided in Subpart H of 

Part 23 of the CFTC Regulations, or any successor regulations related to external business conduct 

standards for Swap Dealers and Major Swap Participants.

c) Participants that are Futures Commission Merchants must verify that each of their Customers are 

Eligible Contract Participants.

d) Participants that are Account Managers must verify that each of their Clients is Eligible Contract 

Participants.

RULE 511 INFORMATION REGARDING ORDERS

a) In accordance with the provisions of SEF Rule 1206, the SEF will make information regarding Orders 

(including prices bid or offered), trades and any other matters it may deem appropriate available to 

Participants and other Persons at such times and in such manner (whether through the Platform, a 

ticker, financial information services or otherwise) as it may consider necessary or advisable from time 

to time.

b) Each Participant or other Person receiving any such information through the Platform may redistribute 

such information only to such extent and in such manner as may be permitted by the SEF from time to 

time.

RULE 512 CUSTOMER TYPE INDICATOR (CTI) CODES

a) Each Participant must identify each transaction executed on the Platform on the record of transactions 

submitted to the SEF with the correct CTI Code. The CTI Codes are as follows:

(1) CTI 1- Transactions initiated and executed by a Participant for his own account, for an account 

he controls or for an account in which he has ownership or financial interest.

(2) CTI 2- Transactions executed for the proprietary account of a Clearing Member or non-Clearing 

member firm.

(3) CTI 3- Transactions where an individual Participant or Authorized Person executes for the 

personal account of another individual Participant, for an account the other individual Participant 

controls or for an account in which the other individual Participant has ownership or financial 

interest.

(4) CTI 4- Any transaction not meeting the definition of CTI 1, 2 or 3.

RULE 513 CANCELED TRADES & AMENDED TRADE 

INFORMATION

a) If the reporting party to a Transaction executed on or pursuant to the Rules of the SEF (including Prime Broker 

Trades) becomes aware of a discrepancy, error or omission in swap transaction and pricing data 

reported to a Swap Data Repository, or if a Transaction executed on or pursuant to the Rules of the 

SEF (including Prime Broker Trades) is canceled or amended, such discrepancy, error, omission, 

cancellation or amendment (as the case may be) must be reported to the SEF by the reporting party 

as soon as technologically practicable after discovery of such discrepancy, error or omission, or 

canceling or amending such Transaction (according to procedures of the SEF, as may be amended 

from time to time), so that the SEF may accurately amend the audit trail and report trade information 

according to Parts 16, 43 and 45 of the CFTC Regulations.
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(1) If a Transaction was submitted for clearing and contains an operational or clerical error (an 

“Error Trade”), the parties to such Transaction shall be permitted to enter into an offsetting or 

correcting trade subject to the following:

i. If the Transaction was rejected from clearing, the parties shall be permitted to execute 

and submit for clearing a new Transaction with the same terms and conditions as the 

Error Trade other than any corrections to any operational or clerical error and the time of 

execution (a “Correcting Trade”). Execution of a Correcting Trade in such circumstance 

must occur as soon as technologically practicable, but no later than one hour after a 

registered Derivatives Clearing Organization, or a derivatives clearing organization that 

the Commission has determined is exempt from registration, provides notice of the 

rejection.

ii. If the Transaction was accepted for clearing, the parties shall be permitted to execute and 

submit for clearing an offsetting trade with terms and conditions that economically reverse 

an error trade that was accepted for clearing and a Correcting Trade. Execution of a 

Correcting Trade in such circumstance must occur as soon as technologically practicable, 

but no later than three days after the Error Trade was accepted for clearing by a 

registered Derivatives Clearing Organization, or a derivatives clearing organization that 

the Commission has determined is exempt from registration.

iii. If a Correcting Trade is rejected from clearing, the parties to the Transaction shall not be 

permitted to execute another Correcting Trade.

b) If a Participant that is a Counterparty to a Prime Broker Trade requests the cancellation of that Prime 

Broker Trade, the Participant must send a cancellation notice to the SEF stating the name and contact 

information of the Prime Broker for the Prime Broker Trade and the reason for cancellation. If the 

Prime Broker confirms the cancellation, the SEF will cancel the Prime Broker Trade.

c) A Prime Broker shall have the right to cancel any Prime Broker Trade that is: (i) executed in excess of 

a limit established by the Prime Broker with respect to the Prime Broker Trade, (ii) executed by a 

Person that was not authorized by the Prime Broker, or (iii) executed for an unauthorized product. The 

Prime Broker shall communicate the cancellation directly to the SEF within 48 hours after the 

execution of the Prime Broker Trade and indicate the reason for the cancellation.

d) Reports or notices of canceled or amended Transactions described in this Rule 513 may be provided 

to the SEF using the electronic cancellation and amendment tool, if available, or by contacting SEF 

support.
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Chapter 6 Supported Transactions

RULE 601 GENERAL

a) The SEF supports Permitted Transactions in Swaps not intended to be cleared, through the execution 

methods detailed in Chapter 7.

b) [Reserved]

RULE 602 BLOCK TRADES

a) [Reserved]

b) The SEF will publish the list of contracts for which it permits and facilitates the bilateral trading and 

execution of Block Trades on its website.

c) The following shall govern Block Trades:

(1) Each Counterparty to a Block Trade (or a Person, Customer or Client on whose behalf a Block 

Trade is executed) must be an Eligible Contract Participant.

(2) Parties to a Swap with a notional amount at or above the Appropriate Minimum Block Size must 

elect to have the Swap treated as a Block Trade in order for the Swap to constitute a Block 

Trade pursuant to this Chapter 6.

(3) A Block Trade must be for a quantity that is at or in excess of the Applicable Minimum Block 

Size. Orders may not be aggregated for different accounts in order to achieve the minimum 

transaction size unless done by a Person who:

i. Is either: (i) a commodity trading advisor registered under Section 4n of the CEA, or 

exempt from registration under the CEA, or a principal thereof, who has discretionary 

trading authority or directs client accounts, (ii) is an investment adviser who has 

discretionary trading authority or directs client accounts and satisfies the criteria of CFTC 

Regulation § 4.7(a)(2)(v), or (iii) is a non-U.S. person, as defined in CFTC rules, 

regulations and/or interpretations who performs a similar role or function as the persons 

described in Rule 602(c)(3)(a)(i) or (ii) and is subject as such to foreign regulation; and

ii. Has more than $25,000,000 in total assets under management.

(4) A broker shall not execute any order by means of a Block Trade for a Customer unless the 

broker has received prior written instruction or consent from the Customer to do so. Such 

instruction or consent may be provided in the power of attorney or similar document by which 

the Customer provides the broker with discretionary trading authority or the authority to direct 

the trading in its account.

(5) The price at which a Block Trade is executed must be fair and reasonable in light of (i) the size 

of the Block Trade, (ii) the prices and sizes of other transactions in the same Contract at the 

relevant time, (iii) the prices and sizes of transactions in other relevant markets at the relevant 

time, and (iv) the circumstances of the markets or the Participants to the Block Trade.

(6) One of the Counterparties or the broker of one of the Persons party to the Block Trade must 

ensure that each Block Trade is reported to the SEF within the time limit set forth in Rule 

401(a)(3).
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(7) Block Trades must be reported to the SEF in accordance with the SEF approved reporting 

method and must include all of the data required by CFTC Regulations Part 43 and 45. The SEF 

will transmit Block Trade transaction and pricing data, including a notice that the Counterparties 

have elected to treat the Swap as a Block Trade, to a Swap Data Repository as soon as 

technologically practicable after receipt of such data. CFTC Regulations prohibit any Swap Data 

Repository from publicly disseminating this data until the expiration of certain time delays as 

specified in CFTC Regulation § 43.5, or any successor regulation thereto.

(8) An executed Block Trade must become a part of the SEF’s audit trail.

RULE 603 PRIME BROKER TRADES

a) A Participant may execute a Prime Broker Trade on or pursuant to the rules of the SEF in accordance 

with the provisions of this Rule 603, in addition to otherwise applicable provisions of the Obligations.

b) Prior to negotiating any Prime Broker Trade on or pursuant to the rules of the SEF, a Participant must 

have in place a Prime Broker Agreement, which shall satisfy those rules contained in SEF Rule 301(b).

c) Each Participant involved in a Prime Broker Trade must notify the Prime Broker as soon as 

technologically possible of each Prime Broker Trade executed on or pursuant to the rules of the SEF to 

which the Prime Broker is a Counterparty, and provide to the Prime Broker the Confirmation for the 

Prime Broker Trade issued by the SEF.
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Chapter 7 Chapter 7 – Execution 

Methods

RULE 701 GENERAL

Transactions executed on the SEF must be executed either on the SEF Central Limit Order Book (“CLOB”), 

the SEF RFQ Platform (“RFQ Platform”), or the SEF RFS Platform (“RFS Platform”) pursuant to this 

chapter.

RULE 702 CENTRAL LIMIT ORDER BOOK (“CLOB”)

a) The CLOB is an electronic price-time priority central limit order book in which Participants trade against 

firm quotes posted by other Participants. When a Participant enters a bid or offer on the CLOB, other 

Participants are notified that such bid or offer has been placed by the bid or offer appearing on the 

CLOB. If there are multiple bids and offers that have the same price, the earliest to arrive in the CLOB 

will be the bid or offer to which the order is matched. If the order exceeds the quantity of the bid or 

offer, the Participant may be filled at the next, best bid or offer for their order.

b) [Reserved]

c) Orders submitted can only match with quotes posted by Participants with whom the order submitter 

has an agreement governing the execution and settlement of Swaps.

d) All Orders submitted to the CLOB are anonymous; provided, that, for Permitted Transactions that are 

not intended to be submitted for clearing contemporaneously with execution, the identity of each 

Counterparty is disclosed to the other Counterparty in the SEF Confirmation at the time of 

confirmation.

e) The CLOB supports the following types of Orders:

(1) For non-deliverable forwards: limit orders, limit orders with discretion, limit orders with reserve, 

and hidden orders.

i. A limit order has a “limit” price, which is the top price to be paid for a buy and the lowest 

price to be given for a sell Order.

ii. A limit order with discretion is a limit order with a discretion value, which allows the 

Participant placing the Order to post a limit order and then take liquidity within a 

discretionary amount using the total Order quantity.

iii. A limit order with reserve is a limit order where the Participant placing the Order can 

control the visible quantity. The “Show” quantity displays a portion of the “Total” quantity 

and holds the balance in reserve, without losing time price priority.

iv. A hidden order is a passive Order that is not visible to other market participants. A hidden 

bid or offer will be executed when all other visible bids or offers (as the case may be) at 

the same price have been exhausted.

(2) For options: limit orders.

i. A limit order has a “limit” price, which is the top price to be paid for a buy and the lowest 

price to be given for a sell Order.
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f) The CLOB supports the following values for Time in Force:

(1) Day: A Day order may rest on the book for the duration of the trading day or until the Participant 

cancels it. Any portion that has not executed by the end of the trading day will expire.

(2) Immediate or Cancel (“IOC”): An IOC order must be executed in whole or in part on the Order 

Book as soon as it is received. Any remaining quantity is cancelled.

g) To enter a bid or offer into the CLOB, a Participant must:

(1) Open an order entry window by clicking on a “Bid,” “Offer,” “Price” or “Quantity” button;

(2) In the order entry window, click on the “Bid” or “Offer” button;

(3) Adjust “Order Type,” “Price,” “Quantity” and “Time in Force” as need be; and

(4) Click the “Place Order” button.

h) Each Participant entering an Order on the CLOB must provide, without limitation:

(1) Identification of the Participant;

(2) Identification of whether the Order is a bid or an offer;

(3) Order type;

(4) Price;

(5) Quantity; and

(6) Time in Force.

RULE 703 REQUEST FOR QUOTE PLATFORM (“RFQ 

PLATFORM”)

a) Transactions may be negotiated by Participants and their Counterparties by use of the RFQ Platform. 

Through the RFQ Platform, Participants can transmit a request for a quote (“RFQ”) to buy or sell a 

specific instrument to other Participants, to which all such Participants may respond. The RFQ 

Platform is a fully disclosed trading system.

b) [Reserved]

c) [Reserved]

d) An RFQ may be sent to any Counterparty with whom the Participant has an agreement governing the 

execution and settlement of Swaps.

e) Negotiation Process

(1) The negotiation process on the RFQ Platform is initiated by entry of an RFQ by an RFQ 

requestor on the Platform. A Participant initiating an RFQ must provide, without limitation:

i. Identification of the Participant;

ii. Identification of whether the request is for a bid, offer, or a two-way quote; and

iii. Quantity.

(2) An RFQ acts as a non-binding solicitation of a non-binding quote and provides essential 

economic terms sufficient for any RFQ requestor’s Counterparty to formulate a responsive 

quote.
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(3) In response to an RFQ, any potential Counterparty receiving an RFQ may reply with a 

responsive quote. Responsive quotes to RFQs are indicative in that they are a solicitation of an 

offer todeal.

(4) In the event that a responsive quote is acceptable to the requestor, the requestor can accept the 

quote and a request to deal will be sent to the responder. If the responder accepts the request, a 

legally enforceable transaction arises and the RFQ process concludes. If the responder rejects 

the request, the RFQ process concludes and no transaction arises.

(5) [Reserved]

(6) In the event that the initial responsive quote from the Counterparty or any resting bid or offer 

from the CLOB is not acceptable to the RFQ requestor, the RFQ responders may continue 

sending responsive quotes until an acceptance is issued or the RFQ process is terminated 

without a transaction.

RULE 704 REQUEST FOR STREAM PLATFORM (“RFS 

PLATFORM”)

a) Transactions may be negotiated by Participants and their Counterparties by use of the RFS Platform. 

Through the RFS Platform, Participants can transmit a request for a stream (“RFS”) subscription to buy 

or sell a specific instrument from other Participants, to which all such Participants may respond. The 

RFS Platform is a fully disclosed trading system.

b) [Reserved]

c) [Reserved]

d) An RFS may only be sent to a Counterparty with whom the Participant has an agreement governing 

the execution and settlement of Swaps.

e) In response to an RFS stream subscription, any potential Counterparty receiving an RFS may reply 

with a responsive stream of quotes.

f) Negotiation Process

(1) Once the requestor has completed the subscription process, the requestor may submit a limit 

order to the RFS Platform. A limit order for an RFS must include without limitation:

i. Identification of the Participant;

ii. Identification of whether the Order is a bid or an offer;

iii. Quantity; and

iv. Time in Force.

(2) The requestor can choose either a “Day” order or an “immediate or cancel” (“IOC”) order for 

Time in Force. If the limit order is marketable it will be sent to the Counterparty of the requestor’s 

choice, or if the requestor elects to have the RFS Platform choose, the RFS Platform will send 

the order to the responder with the best price. If the limit order is not marketable, it will be held in 

the RFS platform until the requestor cancels the order or the order becomes marketable.

(3) In the event that a marketable limit order is sent to a responder, the responder can choose to 

accept or reject the order. If the responder accepts the order, a legally enforceable transaction 

arises and the RFS process for this order concludes. If the responder rejects the order, the RFS 

process for this order concludes.

(4) [Reserved]
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(5) The requestor will continue to receive streaming quotes from a responder until such time as the 

requestor unsubscribes from the responder’s stream or the responder stops sending quotes.

RULE 705 CONFIRMATION PROCEDURES AND 

RECORDS.

a) Each completed Transaction shall be confirmed by a SEF Confirmation to each Participant party 

thereto by technical means as specified in the SEF Rules and in the form and format set forth in Rule 

404.

b) [Reserved]

RULE 706 LEGAL CERTAINTY FOR SEF TRADES.

A transaction entered into on or pursuant to the SEF Rules shall not be void, voidable, subject to rescission, 

otherwise invalidated, or rendered unenforceable as a result of:

a) a violation by the SEF of the provisions of Section 5h of the CEA or CFTC Regulations;

b) any CFTC proceeding to alter or supplement a Rule, term, or condition under Section 8a(7) of the CEA 

or to declare an emergency under Section 8a(9) of the CEA; or

c) any other proceeding the effect of which is to:

(1) alter or supplement a specific term or condition or trading rule or procedure; or

(2) require the SEF to adopt a specific term or condition, trading rule or procedure, or to take or 

refrain from taking a specific action.

RULE 707 POST-TRADE ANONYMITY.

a) Pursuant to the Commission Regulation 37.9(f), neither the SEF nor any person that is subject to its 

rules may, directly or indirectly, including through a third-party service provider, disclose the identity of 

a counterparty for swaps that are executed, pre-arranged or pre-negotiated anonymously on or 

pursuant to the rules of the SEF and that are intended to be submitted for clearing.

b) The compliance date for this Rule 707 for swaps that are subject to the trade execution under section 

2(h)(8) of the Act is November 1, 2020. The compliance date for this rule for swaps that are not subject 

to the trade execution requirement under section 2(h)(8) of the Act is July 5, 2021 
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Chapter 9 Trading Practices and 

Business Conduct

RULE 901 SCOPE

This Chapter 9 applies to all transactions in Contracts, except as otherwise specifically provided herein.

RULE 902 PROCEDURES

a) With respect to trading on or though the Platform, the SEF may adopt, without limitation, procedures 

relating to transactions in Contracts and trading on the Platform, including procedures to:

(1) disseminate the prices of bids and offers on, and trades in, Contracts;

(2) record Contracts and SEF Activity;

(3) perform market surveillance and regulation on matters affecting Contracts and SEF Activity;

(4) establish limits on the number and/or size of Orders that may be submitted by a Participant 

through the Platform;

(5) establish limits on the number of Contracts that may be held by a Customer or Participant;

(6) establish a limit on the maximum daily price fluctuations for any Contract and provide for any 

related restriction or suspension of trading in the Contract; and

(7) require a suspended or expelled Participant, or a Participant with restricted trading rights, to 

have Contracts executed for the Participant to reduce or eliminate any open position or 

exposure to price changes for the Participant in any Contract.

b) The SEF may, in its discretion and at any time, amend any procedures adopted pursuant to Rule 

902(a), and will publish the amendments in a Notice to Participants or in any other manner determined 

appropriate by the SEF.

RULE 903 BUSINESS DAYS AND TRADING HOURS

Except as provided in Rule 209 with respect to Emergencies, the SEF shall determine and publish a Notice 

to Participants listing the Business Days and Holidays of the SEF and the Trading Hours for each Contract.

RULE 904 RULE VIOLATIONS

It shall be a violation for a Participant to violate any SEF Rule or any agreement made with the SEF, or to 

engage in fraud, dishonorable or dishonest conduct, or in conduct which is inconsistent with just and 

equitable principles of trade.
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RULE 905 FRAUDULENT ACTS PROHIBITED

No Participant shall engage, or attempt to engage, in any fraudulent act or any scheme to defraud, deceive, 

trick or mislead in connection with or related to any SEF Activity.

RULE 906 FICTITIOUS, WASH OR NON-COMPETITIVE 

TRANSACTIONS PROHIBITED

No Participant shall create, place or accept, or attempt to create, place or accept, fictitious transactions, 

Wash Transactions, or non-competitive transactions, except in the case of non-competitive transactions, as 

otherwise authorized by the SEF Rules, or execute, or attempt to execute, any such Order if the Participant 

or any of its Authorized Persons know or should have known that the transaction is or was a fictitious 

transaction, Wash Transaction, or non-competitive transaction. No person shall place or accept, or attempt 

to place or accept, buy and sell orders in the same Unique Swap Identifier, where the person knows or 

should have known that the purpose of the orders is to avoid taking a bona fide market position exposed to 

market risk. Buy and sell Orders for different accounts with common beneficial ownership that are entered 

with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on 

Wash Transactions. Additionally, no Person shall knowingly execute or accommodate, or attempt to 

execute or accommodate, the Execution of such Orders by direct or indirect means.

RULE 907 MARKET DISRUPTION PROHIBITED

Orders entered into the Platform for the purpose of upsetting the equilibrium of the market in any Contract 

or creating a condition in which prices do not or will not reflect fair market values are prohibited, and any 

Participant who makes or assists in entering any such Order with knowledge of the purpose thereof or who, 

with such knowledge, in any way assists in carrying out any plan or scheme for the entering of any such 

Order, will be deemed to have engaged in an act detrimental to the SEF.

RULE 908 MANIPULATION AND FRAUDULENT 

CONDUCT PROHIBITED

a) No Participant shall attempt to manipulate or manipulate the market in any Contract; provided, 

however, that nothing in this Rule 908 shall be construed to require any Person to disclose to another 

Person non-public information that may be material to the market price, rate, or level of a particular 

transaction, except as necessary to make any statement made to the other Person in or in connection 

with the transaction not misleading in any material respect.

b) No Participant shall directly or indirectly, in connection with any Contract in interstate commerce, 

intentionally or recklessly:

(1) Use or employ, or attempt to use or employ, any manipulative device, scheme, or artifice to 

defraud;

(2) Make, or attempt to make, any untrue or misleading statement of a material fact or to omit to 

state a material fact necessary in order to make the statements made not untrue or misleading;

(3) Engage, or attempt to engage, in any act, practice, or course of business, which operates or 

would operate as a fraud or deceit upon any Person; or,
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(4) Deliver or cause to be delivered, or attempt to deliver or cause to be delivered, for transmission 

through the mails or interstate commerce, by any means of communication whatsoever, a false 

or misleading or inaccurate report concerning market information or conditions that affect or tend 

to affect the price of any Contract in interstate commerce, knowing, or acting in reckless 

disregard of the fact that such report is false, misleading or inaccurate; provided, however, that 

no violation of this Rule 908 shall exist where the Participant mistakenly transmits, in good faith, 

false or misleading or inaccurate information to a price reporting service.

c) No Participant shall directly or indirectly, manipulate or attempt to manipulate the price of any Swap, or 

of any Contract in interstate commerce.

RULE 909 DISRUPTIVE TRADING PRACTICES 

PROHIBITED

No Participant shall engage in any trading, practice, or conduct that constitutes a “disruptive trading 

practice,” as such term is described in Section 4c(a)(5) of the CEA or in interpretive guidance issued by the 

CFTC.

RULE 910 ABUSIVE TRADING PRACTICES 

PROHIBITED

No Participant shall engage in any abusive trading practice, including front-running, Wash Transactions, 

pre-arranged trading (except with regard to Block Trades), fraudulent trading, fictitious sales, the intentional 

or reckless disregard for the orderly execution of transactions during the closing period, the use of swaps to 

defraud or money passes.

RULE 911 PROHIBITION OF MISSTATEMENTS

No Participant shall make any knowing misstatement of a material fact to the SEF, any SEF Official, any 

Board committee or SEF panel, or the Regulatory Services Provider.

RULE 912 ACTS DETRIMENTAL TO WELFARE OF THE 

SEF PROHIBITED

No Participant shall engage in any act that is detrimental to the SEF.

RULE 913 ADHERENCE TO LAW

No Participant shall engage in conduct that is a violation of the CEA or CFTC Regulations.

RULE 914 SUPERVISION 

A Participant shall establish, maintain and administer reasonable supervisory procedures to monitor the 

compliance of Authorized Persons with the SEF Rules and any applicable provisions of the CEA or CFTC 
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Regulations, and such Participant may be held accountable for the actions, failures or omissions of such 

Authorized Persons.

RULE 915 MISUSE OF THE PLATFORM

Misuse of the Platform is strictly prohibited. It shall be deemed an act detrimental to the SEF to permit 

unauthorized use of the Platform, to assist any Person in obtaining unauthorized access to the Platform, to 

trade on the Platform without a User Agreement (except for Sponsored Persons), to alter the equipment 

associated with the Platform (except with the SEF’s consent), to interfere with the operation of the Platform, 

to intercept or interfere with information provided thereby, or in any way to use the Platform in a manner 

contrary to the SEF Rules.

RULE 916 WITHHOLDING ORDERS PROHIBITED

Any Participant entering Orders on the Platform shall not withhold or withdraw from the market any Order, 

or any part of an Order, for the benefit of any Person other than for the Customer for whom the Participant 

is placing the Order.

RULE 917 PRIORITY OF CUSTOMERS’ ORDERS

No Participant shall enter an Order into the Platform for his own account, an account in which he has a 

direct or indirect financial interest or an account over which he has discretionary trading authority, including, 

without limitation, an Order allowing discretion as to time and price, when such Participant is in possession 

of any un-submitted Customer Order based on the same Contract and with the same fixing date or 

expiration date and that the Platform is capable of accepting.

RULE 918 HANDLING OF CUSTOMER ORDERS

a) No Participant in possession of a Customer Order shall knowingly trade ahead of a Customer Order or 

take, directly or indirectly, the opposite side of such Order for its own account, an account in which it 

has a direct or indirect financial interest, or an account over which it has discretionary trading authority.

b) No Participant in possession of a Customer Order shall engage in accommodation trading or improper 

cross-trading.

c) Exceptions. The restriction in this Rule 918 shall not apply to the following:

(1) Transactions executed pursuant to SEF Rule 602 (Block Trades); or

(2) Transactions executed pursuant to SEF Rule 920 (15 Second Rule).

RULE 919 DISCLOSING ORDERS PROHIBITED

No Participant shall disclose another Customer’s Order to buy or sell except to a designated SEF Official or 

the CFTC, and no Participant shall solicit or induce another Participant to disclose Order information. No 

Person shall take action or direct another to take action based on non-public Order information, however 

acquired. The mere statement of opinions or indications of the price at which a market may open or resume 

trading does not constitute a violation of this rule.
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RULE 920 [RESERVED] 

RULE 921 PRE-ARRANGED AND NONCOMPETITIVE 

TRADES PROHIBITED

a) No Person shall pre-arrange any purchase or sale or noncompetitively execute any transaction, except 

in accordance with Section (b).

b) The foregoing restriction shall not apply to Transactions executed pursuant to SEF Rule 602 (Block 

Trades), and, for the avoidance of doubt, does not prohibit Pre-Execution Communications with 

respect to RFQ Transactions pursuant to SEF Rule 703 or RFS Transactions pursuant to Rule 704.

RULE 922 RESPONSIBILITY FOR CUSTOMER 

ORDERS

a) Standard of Responsibility.

(1) A Participant shall exercise due diligence in the handling and execution of Customer Orders. 

Failure to act with due diligence shall constitute negligence. In the case of a dispute as to 

whether a Participant has exercised due diligence, the appropriate arbitration or disciplinary 

committee is authorized to determine whether the Participant was negligent and, if so, whether 

an adjustment is due to the Customer.

(2) A Participant is prohibited from directly or indirectly guaranteeing the execution of an Order or 

any of its terms such as the quantity or price. A Participant may only report an execution that 

has been effected through the Platform or has been executed under Chapter 7. This Rule 922(a) 

shall not be construed to prevent a Participant from assuming or sharing in the losses resulting 

from an error or the mishandling of an Order provided such action is done in accordance with 

the SEF Rules as well as Applicable Law.

b) Liability for Negligence. A Participant may not be held responsible for executing a Customer Order or 

failing to execute a Customer Order unless such Participant was negligent. A Participant may not 

compel an adjustment from another Participant in the absence of a bona-fide dispute regarding 

negligence. Participants shall document all adjustments and shall make and retain a record which 

contains the date the adjustment was received, the name of the Participant making the adjustment, the 

account to which the adjustment was credited, the amount of the adjustment, the Order number and 

the reason for the adjustment. Such records must be provided to the Market Regulation Department 

upon request.

RULE 923 DISCRETIONARY ORDERS

No Participant shall submit a discretionary order to the Platform for any account of another Person, without 

the prior specific written consent of such other Person to the exercise of such discretion.
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RULE 924 POSITION LIMITS

a) To reduce the potential threat of market manipulation or congestion, the SEF shall adopt for each of 

the Contracts listed on the Platform, as is necessary and appropriate, position limitations or position 

accountability levels for speculators.

b) Except as otherwise provided by these SEF Rules, no Person, including a Participant, may hold or 

control a position in excess of such position limits, and a Participant may not maintain a position in 

excess of such position limits for a Client or Customer if such Participant knows, or with reasonable 

care should know, that such position will cause such Client or Customer to exceed the applicable 

position limits.

c) Position limits shall apply to (i) all positions in accounts for which any Person, by power of attorney or 

otherwise, directly or indirectly holds positions or controls trading, and (ii) positions held by two or more 

Persons acting pursuant to an express or implied agreement or understanding, as if the positions were 

held by, or the trading of the positions were done by, a single Person.

RULE 925 EXEMPTIONS FROM POSITION LIMITS

The SEF may grant exemptions from position limits under Rule 924 for bona fide hedging positions and risk 

management positions and otherwise on good cause shown and to the extent permitted by Applicable Law. 

Any Person seeking an exemption from the position limits referred to in Rule 924 must file an application 

with the SEF in the manner and within the time limits prescribed by the SEF. The SEF shall notify the 

applicant whether the exemption has been approved and whether the SEF has imposed any limitations or 

conditions on the exemption. The decision of the SEF shall be final.

RULE 926 POSITION ACCOUNTABILITY

a) The SEF may establish a position accountability level for any Swap. Any Person, including a 

Participant, who owns or controls Swaps in excess of the applicable position accountability level shall 

provide to the SEF at its request any information regarding the nature of the position, trading strategy 

or hedging activities, if applicable, and if ordered by the SEF, shall liquidate any or all of the positions, 

or not increase the size of any such position.

b) For purposes of this Rule, all positions in accounts for which a Person, by power of attorney or 

otherwise, directly or indirectly controls trading shall be included with the positions held by such 

Person. The provisions of this Rule shall apply to positions held by two or more Persons acting 

pursuant to an express or implied agreement or understanding, as if the positions were held by a 

single Person.

RULE 927 PLATFORM ACCESS RESTRICTIONS

All individuals entering Customer Orders in other than a clerical capacity must have appropriate industry 

registration. Customer Orders may be entered only from the premises of an entity registered to conduct 

Customer business.
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RULE 928 PRE-EXECUTION CREDIT CHECKS

Pre-execution credit checks will be performed for Permitted Transactions executed on the Order Book. 

If a credit check fails, a trade is not permitted.

RULE 929 RISK CONTROLS FOR TRADING

a) The SEF reserves the right to modify, adjust, or cancel any Transaction, including Block Trades, that it 

determines in its sole discretion to be unlawful, off market, the result of error, or otherwise incompatible 

with these SEF Rules, the User Agreement, or the efficient and secure operation of the SEF, including, 

but not limited to, excessive electronic traffic sent by any Participant, to the SEF.

b) The SEF reserves the right to modify or adjust trade prices, or cancel any Transaction, including Block 

Trades, when such action is necessary to mitigate market disrupting events caused by malfunctions in 

the SEF’s systems or the Platform or errors in orders submitted by Participants, Clients, Customers or 

Sponsored Persons.

c) Notwithstanding any other provisions of this Rule, the SEF may modify or adjust trade prices or cancel 

any Transaction if the SEF determines that allowing the Transaction to stand as executed may have a 

material, adverse effect on the integrity of the market.

d) A decision by the SEF pursuant to this Rule 929 to modify or adjust trade prices, or cancel a 

Transaction, will be made as soon as practicable, and the SEF shall notify Participants and the Swap 

Data Repository as soon as practicable: (1) that a trade is under review; and (2) of the SEF’s final 

determination with respect to the modification, adjustment or cancellation. In deciding whether or not to 

modify or adjust trade prices, or cancel a Transaction, the SEF may consider any information that it 

determines to be relevant, including, but not limited to, the last trade price of the Swap, a better bid or 

offer that was available on the Platform, the price of the same or related Swap for a different maturity 

date, the price of the same or related Swap established in another venue or another market, the 

market conditions at the time of the trade, indications of interest, and responses to an RFQ.

e) The SEF shall have the right to take any action to reduce the potential of market disruption, including 

but not limited to, market restrictions that pause or halt trading in market conditions prescribed by the 

SEF if such action is in the best interest of the swap markets.

f) The SEF sets a default order size limit for all Orders (regardless of currency pair) submitted to the 

Platform, which the SEF may adjust from time to time. Participants may set lower limits, which can be 

established across all currency pairs or for specific currency pairs.

RULE 930 [RESERVED]

RULE 931 LIMITATION OF LIABILITY, NO 

WARRANTIES

a) NEITHER THE SEF (INCLUDING ITS SUBSIDIARIES AND AFFILIATES AND ANY CONTRACTORS 

PROVIDING SERVICES TO THE SEF), NOR ANY OF THEIR RESPECTIVE DIRECTORS, 

OFFICERS, EMPLOYEES, AGENTS, CONSULTANTS, AND LICENSORS (THE “DISCLAIMING 

PARTY” OR “DISCLAIMING PARTIES”) SHALL BE LIABLE TO ANY PERSON FOR ANY LOSSES, 

DAMAGES, COSTS OR EXPENSES (INCLUDING, BUT NOT LIMITED TO, LOSS OF PROFITS, 
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LOSS OF USE, AND DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE 

DAMAGES), ARISING FROM:

(1) ANY FAILURE, MALFUNCTION, FAULT IN DELIVERY, DELAY, OMISSION, SUSPENSION, 

INACCURACY, INTERRUPTION, TERMINATION, OR ANY OTHER EVENT, IN CONNECTION 

WITH THE FURNISHING, PERFORMANCE, OPERATION, MAINTENANCE, USE OF OR 

INABILITY TO USE ALL OR ANY PART OF ANY OF THE SYSTEMS AND SERVICES OF THE 

PLATFORM, OR SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT SUCH 

SYSTEMS AND SERVICES, INCLUDING WITHOUT LIMITATION ELECTRONIC ORDER 

ENTRY/DELIVERY, TRADING THROUGH ANY ELECTRONIC MEANS, ELECTRONIC 

COMMUNICATION OF MARKET DATA OR INFORMATION, WORKSTATIONS USED BY 

PARTICIPANTS, PRICE REPORTING SYSTEMS AND ANY AND ALL TERMINALS, 

COMMUNICATIONS NETWORKS, CENTRAL COMPUTERS, SOFTWARE, HARDWARE, AND 

FIRMWARE RELATING THERETO; OR

(2) ANY FAILURE OR MALFUNCTION, FAULT IN DELIVERY, DELAY, OMISSION, 

SUSPENSION, INACCURACY, INTERRUPTION OR TERMINATION, OR ANY OTHER 

EVENT, OF ANY SYSTEM OR SERVICE OF THE SEF, OR SERVICES, EQUIPMENT OR 

FACILITIES USED TO SUPPORT SUCH SYSTEMS OR SERVICES, CAUSED BY ANY THIRD 

PARTIES INCLUDING, BUT NOT LIMITED TO, INDEPENDENT SOFTWARE VENDORS AND 

NETWORK PROVIDERS; OR

(3) ANY ERRORS OR INACCURACIES IN INFORMATION PROVIDED BY THE SEF OR ANY OF 

THE SEF’S SYSTEMS, SERVICES OR FACILITIES; OR

(4) ANY UNAUTHORIZED ACCESS TO OR UNAUTHORIZED USE OF ANY OF THE SEF’S 

SYSTEMS, SERVICES, EQUIPMENT OR FACILITIES BY ANY PERSON.

THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY WHETHER A CLAIM ARISES IN 

CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, CONTRIBUTION OR OTHERWISE 

AND WHETHER THE CLAIM IS BROUGHT DIRECTLY OR AS A THIRD PARTY CLAIM. THE 

FOREGOING LIMITATION OF LIABILITY SHALL NOT APPLY TO ANY LIABILITIES ARISING 

OUT OF A VIOLATION BY THE SEF OF THE CEA AND/OR CFTC REGULATIONS, 

INCLUDING PART 37 OF THE CFTC’S REGULATIONS. THE LIMITATION OF LIABILITY 

CONTAINED IN SUBSECTION (a) OF THIS RULE 931 SHALL NOT APPLY TO THE SEF IN 

INSTANCES WHERE A DISCLAIMING PARTY HAS BEEN FINALLY ADJUDICATED TO HAVE 

ENGAGED IN GROSS NEGLIGENCE OR WILLFUL OR WANTON MISCONDUCT.

b) NOTWITHSTANDING SUBSECTION (a), (e), OR (f) OF THIS RULE 931, IN NO EVENT SHALL ANY 

PERSON BRING ANY LEGAL ACTION (WHETHER IN TORT, NEGLIGENCE, OR BREACH OF 

CONTRACT) FOR ANY LOSSES DAMAGES, COSTS OR EXPENSES INCLUDING, BUT NOT 

LIMITED TO LOSS OF PROFITS, LOSS OF USE, DIRECT, SPECIAL, PUNITIVE, INDIRECT, 

INCIDENTAL OR CONSEQUENTIAL DAMAGES, ARISING FROM THE USE OF THE PLATFORM.

c) THERE ARE NO EXPRESS OR IMPLIED WARRANTIES OR REPRESENTATIONS (INCLUDING 

BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR 

PURPOSE OR USE) PROVIDED BY THE DISCLAIMING PARTY OR DISCLAIMING PARTIES 

RELATING TO ANY SYSTEMS OR SERVICES OF THE SEF OR SERVICES, EQUIPMENT OR 

FACILITIES USED TO SUPPORT SUCH SYSTEMS OR SERVICES, INCLUDING THE SEF 

PLATFORM.

d) ANY DISPUTE ARISING OUT OF THE USE OF SYSTEMS OR SERVICES OF THE SEF OR 

SERVICES, EQUIPMENT, OR FACILITIES USED TO SUPPORT SUCH SYSTEMS OR SERVICES 

IN WHICH THE DISCLAIMING PARTY OR DISCLAIMING PARTIES IS A PARTY SHALL BE 

ARBITRATED PURSUANT TO CHAPTER 11. ANY ARBITRATION SHALL BE BROUGHT WITHIN 

THE PERIOD PRESCRIBED BY CHAPTER 11. ANY OTHER ACTIONS, SUITS OR PROCEEDINGS 

AGAINST THE DISCLAIMING PARTY OR DISCLAIMING PARTIES MUST BE BROUGHT WITHIN 

TWO (2) YEARS FROM THE TIME THAT A CAUSE OF ACTION HAS ACCRUED. THIS 
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PARAGRAPH (d) SHALL IN NO WAY BE CONSTRUED TO LIMIT A PARTY’S OBLIGATION TO 

ARBITRATE ITS CLAIM OR TO CREATE A CAUSE OF ACTION AND SHALL NOT AUTHORIZE AN 

ACTION THAT WOULD OTHERWISE BE PROHIBITED BY THE SEF RULES. IF FOR ANY 

REASON, A COURT OF COMPETENT JURISDICTION FINDS THAT A DISPUTE IS NOT 

ARBITRABLE, SUCH DISPUTE MAY ONLY BE LITIGATED IN THE COUNTY OF NEW YORK IN 

THE STATE OF NEW YORK AND WILL BE GOVERNED BY THE LAWS OF THE STATE OF NEW 

YORK WITHOUT REGARD TO ANY PROVISIONS OF NEW YORK LAW THAT WOULD APPLY THE 

SUBSTANTIVE LAW OF A DIFFERENT JURISDICTION.

e) THE SEF MAY, IN ITS SOLE DISCRETION, ASSUME RESPONSIBILITY FOR DIRECT, OUT-OFPOCKET LOSSES DIRECTLY CAUSED BY THE NEGLIGENCE OF A DISCLAIMING PARTY OR 

PARTIES AND/OR ORDER STATUS ERRORS PROVIDED BY THE SEF OR A SEF SYSTEM, 

EQUIPMENT, SERVICE OR FACILITY. NOTWITHSTANDING THE ABOVE, i) THE SEF’S TOTAL 

COMBINED AGGREGATE OBLIGATIONS SHALL NOT EXCEED $10,000 FOR ALL LOSSES FROM 

ALL CAUSES SUFFERED ON A SINGLE DAY; $25,000 FOR ALL LOSSES SUFFERED FROM ALL 

CAUSES IN A SINGLE CALENDAR MONTH; AND $500,000 FOR ALL LOSSES FROM ALL CAUSES 

SUFFERED IN A SINGLE CALENDAR YEAR. ANY DISPUTED CLAIM PURSUANT TO THIS 

PARAGRAPH (e) MUST BE ARBITRATED PURSUANT TO CHAPTER 11.

f) IN NO EVENT SHALL THE SEF’S TOTAL COMBINED AGGREGATE LIABILITY FOR ALL CLAIMS 

ARISING OUT OF ANY FAILURES, MALFUNCTIONS, FAULTS IN DELIVERY, DELAYS, 

OMISSIONS, SUSPENSIONS, INACCURACIES, INTERRUPTIONS, TERMINATIONS, OR ANY 

OTHER CAUSES, IN CONNECTION WITH THE FURNISHING, PERFORMANCE, OPERATION, 

MAINTENANCE, USE OF OR INABILITY TO USE ALL OR ANY PART OF ANY OF THE SEF’S 

SYSTEMS OR SERVICES, OR SERVICES, EQUIPMENT OR FACILITIES USED TO SUPPORT 

SUCH SYSTEMS AND SERVICES, OR THE NEGLIGENCE OF THE SEF STAFF EXCEED $500,000 

IN ANY GIVEN CALENDAR YEAR. IF THE NUMBER OF ALLOWED CLAIMS ARISING OUT OF ANY 

FAILURES OR MALFUNCTIONS ON A SINGLE DAY OR SINGLE MONTH CANNOT BE FULLY 

SATISFIED BECAUSE OF THE ABOVE DOLLAR LIMITATIONS, ALL SUCH CLAIMS SHALL BE 

LIMITED TO A PRO RATA SHARE OF THE MAXIMUM AMOUNT FOR THE RESPECTIVE PERIOD.
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Chapter 10 Disciplinary Rules

RULE 1001 GENERAL 

a) All Participants, Account Managers, Authorized Persons, Authorized Representatives, Clients, 

Customers and Sponsored Persons (collectively “SEF Market Participants”) shall be subject to the 

SEF’s jurisdiction. All SEF Market Participants are subject to this Chapter 10 if they, or with respect to 

a Participant, any other Person using its Legal Entity Identifier, are alleged to have violated, to have 

aided and abetted a violation, to be violating, or to be about to violate, any SEF Rule or any provision 

of Applicable Law for which the SEF possesses disciplinary jurisdiction.

b) The Market Regulation Department has the authority to: (i) initiate and conduct inquiries and 

investigations; (ii) prepare investigative reports and make recommendations concerning initiating 

disciplinary proceedings; and (iii) prosecute alleged violations within the SEF’s disciplinary jurisdiction.

c) Each SEF Market Participant: (i) is obligated to appear and testify and respond in writing to 

interrogatories within the time period required by the Market Regulation Department in connection with: 

(A) any Obligation; (B) any inquiry or investigation; or

d) (C) any preparation by and presentation during a Disciplinary Action; (ii) is obligated to produce all 

books, records, papers, documents or other tangible evidence in its, his or her possession, custody or 

control within the time period required by the Market Regulation Department in connection with: (A) 

any Obligation; (B) any inquiry or investigation; or (C) any preparation by and presentation during a 

Disciplinary Action; and (iii) may not impede or delay any Disciplinary Action.

e) The SEF, through the Market Regulation Department, will promptly prosecute possible rule violations 

within the SEF’s disciplinary jurisdiction.

f) The SEF, through the Regulatory Services Provider, if any, and the Disciplinary Panel, will conduct 

inquiries, investigations, disciplinary proceedings, summary impositions of fines, summary 

suspensions or other summary actions in accordance with this Chapter 10.

g) No SEF Official or Officer will interfere with or attempt to influence the process or resolution of any 

inquiry, investigation, or disciplinary proceeding. No Director will interfere with or attempt to influence 

the process or resolution of any Disciplinary Action except to the extent provided under the SEF Rules.

h) Any SEF Market Participant may be represented by counsel during any inquiry, investigation, 

disciplinary or appeals proceeding, summary imposition of fines, summary suspension or other 

summary actions pursuant to this Chapter 10.

i) Participant Liability – Individual and Joint Liability/Controlling Person Liability.

(1) The SEF may hold a Participant liable for, and impose sanctions against such Participant, for 

such Participant’s own acts and omissions that constitute a violation as well as for the acts and 

omissions of each (A) Authorized Person authorized by such Participant, (B) other Person using 

a Legal Entity Identifier of such Participant or (C) other agent or representative of such 

Participant, in each case, that constitute a violation as if such violation were that of the 

Participant.

(2) The SEF may hold an Authorized Person liable for, and impose sanctions against such 

Authorized Person for such Authorized Person’s own acts and omissions that constitute a 

violation as well as or for the acts and omissions of any other agent or representative of such 

Authorized Person that constitute a violation as if such violation were that of the Authorized 

Person.

(3) [Reserved]
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j) Ex Parte Communications.

(1) A Person subject to a disciplinary proceeding (and any counsel or representative of such 

Person) and the Market Regulation Department (and any counsel or representative of the 

Market Regulation Department) shall not knowingly make or cause to be made an ex parte 

communication relevant to the merits of a disciplinary proceeding to any member of the 

Disciplinary Panel hearing such proceeding.

(2) Members of a Disciplinary Panel shall not knowingly make or cause to be made an ex parte 

communication relevant to the merits of a disciplinary proceeding to any Person subject to such 

proceeding (and any counsel or representative of such Person) and the Market Regulation 

Department (and any counsel or representative of the Market Regulation Department).

(3) Any Person who receives, makes or learns of any communication that is prohibited by this rule 

shall promptly give notice of such communication and any response thereto to the Market 

Regulation Department and all parties to the proceeding to which the communication relates.

(4) A Person shall not be deemed to have violated this rule if the Person refuses an attempted 

communication concerning the merits of a proceeding as soon as it becomes apparent the 

communication concerns the merits.

RULE 1002 INVESTIGATIONS AND INVESTIGATION 

REPORTS

a) Procedures.

(1) The SEF’s Market Regulation Department shall initiate an investigation upon the receipt of a 

request from the CFTC or upon the discovery or receipt of information that, in the judgment of 

the Market Regulation Department, indicates a possible basis for finding that a violation has 

occurred or will occur.

(2) Absent mitigating circumstances, a Market Regulation Department investigation must be 

completed no later than twelve (12) months after the date that such investigation is opened. If a 

Market Regulation Department investigation will take longer than twelve (12) months to 

complete, the Market Regulation Department must explain the reasons in writing to the Chief 

Compliance Officer.

b) Investigation Reports.

(1) If the Market Regulation Department determines that a reasonable basis exists for finding a 

violation of the SEF Rules or Applicable Law, the Market Regulation Department must submit a 

written report to the Review Panel, which shall include: all relevant facts and evidence gathered; 

a summary of the reason the investigation was initiated; a summary of the complaint, if any; a 

description of the SEF Market Participant’s disciplinary history (including warning letter); the 

Market Regulation Department’s analysis and conclusions; and a recommendation as to 

whether Disciplinary Action should be pursued.

(2) If the Market Regulation Department determines that no reasonable basis exists for finding a 

violation of the SEF Rules or Applicable Law, the Market Regulation Department must 

nonetheless submit a written report to the Chief Compliance Officer, which shall include: the 

reason the investigation was initiated; a summary of the complaint, if any; the relevant facts; 

Market Regulation Department’s analysis and conclusions; and if applicable, any 

recommendation that a disciplinary committee issue a warning letter. If the Market Regulation 

Department recommends that a warning letter be issued to a SEF Market Participant, the 

investigation report shall include a copy of the letter as well as the SEF Market Participant’s 

disciplinary history at the SEF, including copies of warning letters.
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c) Warning Letters.

(1) After conducting an investigation pursuant to Rule 1002(a), the Market Regulation Department 

may recommend to the Chief Compliance Officer that the SEF issue a warning letter to a SEF 

Market Participant. Upon such recommendation, the Chief Compliance Officer may issue a 

warning letter to any SEF Market Participant. A warning letter is not a penalty or an indication 

that a finding of a violation has been made. No more than one warning letter may be issued per 

rolling 12-month period for the same violation by the same Person.

RULE 1003 DISCIPLINARY PANELS

a) Disciplinary Panel Composition.

(1) The SEF, through the Regulatory Services Provider, if any, shall have a Review Panel and a 

Hearing Panel (collectively, the “Disciplinary Panel”).

(2) Each Disciplinary Panel shall consist of no fewer than three members, who shall be appointed 

by the Chief Compliance Officer or the Regulatory Services Provider, if any. Each Disciplinary 

Panel shall represent the interests of a diversity of Participants so as to ensure fairness and to 

prevent special treatment or preference for any Person in the conduct of the Disciplinary Panel's 

responsibilities, and shall consist of at least one individual who is not an employee of the SEF, a 

member of the Regulatory Services Provider, an employee of a member of the Regulatory 

Services Provider, or an employee of the Regulatory Services Provider. No member of the 

Market Regulation Department or Person involved in adjudicating any other stage of a 

proceeding shall participate in a Disciplinary Panel for such proceeding. Additionally, a 

Disciplinary Panel shall consist of at least one individual who is not a Participant or an employee 

of a Participant with respect to any disciplinary action in which the subject of the action is a 

member of the Board or the Disciplinary Panel, or for any disciplinary action in which any of the 

charged, alleged or adjudicated violations involve manipulation or attempted manipulation of the 

price of a Contract, or conduct which directly results in financial harm to a Person that is not a 

Participant of the SEF.

(3) All information, records, materials and documents provided to the Disciplinary Panels and all 

deliberations, testimony, information, records, materials and documents related thereto shall be 

treated as non-public and confidential and shall not be disclosed, except as necessary to further 

an investigation or as required by law.

b) Review Panel. The Review Panel is responsible for determining whether a reasonable basis exists for 

finding a violation of the SEF Rules, and for authorizing the issuance of notices of charges against 

Persons alleged to have committed violations if the Review Panel believes that the matter should be 

adjudicated. No member of a Review Panel may have a financial, personal, or other direct interest in 

the matter under consideration, or a material conflict of interest (as described in Rule 210) with the 

Person alleged to have committed violations, any potential party to the proceeding, or a Person known 

by the member to be an employer, employee, or co-worker of the Person alleged to have committed 

violations or a potential party to the proceeding.

c) Hearing Panel. The Hearing Panel is responsible for adjudicating disciplinary cases pursuant to a 

notice of charges authorized by a Review Panel. No member of a Hearing Panel may have a financial, 

personal, or other direct interest in the matter under consideration, or a material conflict of interest (as 

described in Rule 210) with the respondent, any party to the proceeding, a witness or Person that the 

Hearing Panel reasonably believes will be a witness (a “potential witness”), or a Person known by the 

member to be an employer, employee, or co-worker of the respondent, a party, or a witness or 

potential witness.
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RULE 1004 REVIEW OF INVESTIGATORY REPORT

a) Within thirty (30) days of receiving a completed investigation report pursuant to Rule 1002, a Review 

Panel must take one of the following actions:

(1) If the Review Panel determines that additional investigation or evidence is needed, it must 

promptly direct the Market Regulation Department to conduct further investigation.

(2) If the Review Panel determines that no reasonable basis exists for finding a violation or that 

prosecution is otherwise unwarranted, it may direct that no further action be taken. Such 

determination must be in writing, and must include a written statement setting forth the facts and 

analysis supporting the decision.

(3) If the Review Panel determines that a reasonable basis exists for finding a violation and 

adjudication is warranted, it must direct that the person or entity alleged to have committed the 

violation be served with a notice of charges and must proceed in accordance with the rules of 

this section.

RULE 1005 NOTICE OF CHARGES

a) If the Review Panel directs that a respondent be served with a notice of charges pursuant to Rule 

1004(a)(3), the Market Regulation Department shall prepare and serve a notice of charges.

b) A notice of charges will state the acts, conduct, or practices in which the respondent is alleged to have 

engaged; state the rule, or rules, alleged to have been violated (or about to be violated); advise the 

respondent that he is entitled, upon request, to a hearing; prescribe the period within which a hearing 

on the charges may be requested, which shall not be less than twenty

c) (20) days; advise the respondent that he has the right to be represented by legal counsel or any other 

representative of its choosing in all succeeding stages of the disciplinary process; advise the 

respondent that any failure to request a hearing within the period stated, except for good cause, will be 

deemed to constitute a waiver of the right to a hearing; and advise the respondent that any allegation 

in the notice of charges that is not expressly denied will be deemed to be admitted.

d) Any notice of charges or other documents to be served pursuant to this Chapter 9 may be served upon 

the respondent and service shall be deemed complete either personally or by leaving the same at his 

or her place of business; by deposit in the United States mail, postage prepaid, via registered or 

certified mail addressed to the respondent at the address as it appears on the books and records of 

the SEF; or via electronic mail to the electronic mail address as it appears on the books and records of 

the SEF.

e) Upon being served with a notice of charges, a respondent will have the right to be represented by legal 

counsel or any other representative of its choosing in all succeeding stages of the disciplinary process.

RULE 1006 ANSWER TO NOTICE OF CHARGES

a) In General. If the respondent determines to answer a notice of charges, the respondent must, in 

writing:

(1) specify the allegations that the respondent denies or admits;

(2) specify the allegations that the respondent does not have sufficient information to either deny or 

admit;

(3) specify any specific facts that contradict the notice of charges;
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(4) specify any affirmative defenses to the notice of charges; and

(5) sign and serve the answer on the Chief Compliance Officer.

b) Failure to Respond.

(1) Any failure by the respondent to timely serve an answer to a notice of charges will be deemed to 

be an admission to the allegations in such notice. Any failure by the respondent to answer one 

or more allegations in a notice of charges will be deemed to be an admission of that allegation 

or those allegations. Any allegation in a notice of charges that the respondent fails to expressly 

deny will be deemed to be admitted. A general denial by the respondent, without more, will not 

satisfy the requirements of paragraph (a) above.

(2) If a respondent admits to allegations through such a failure to respond, the Hearing Panel shall 

impose appropriate sanctions.

(3) Before imposing sanctions pursuant to Rule 1006(b)(2), the Hearing Panel will notify the 

respondent in writing of any sanction to be imposed and advise the respondent that it may 

request a hearing on such sanction within a specified period of time. If a respondent fails to 

request a hearing within twenty (20) days after being served with such notice, the respondent 

will be deemed to have accepted the sanction.

c) Denial of Charges and Right to Hearing.

(1) If a respondent requests a hearing on a charge that is denied pursuant to Rule 1006(a), or on a 

sanction set by the Hearing Panel pursuant to Rule 1006(b)(3), the respondent shall be entitled 

to a hearing in accordance with Rule 1009.

(2) Except for good cause shown, the hearing will be concerned only with those charges denied 

and/or sanctions set by the Hearing Panel under Rule 1006(b)(3) for which a hearing has been 

requested.

RULE 1007 SETTLEMENTS 

a) A respondent or potential respondent may at any time propose in writing an offer of settlement related 

to anticipated or instituted disciplinary proceedings.

b) Any offer of settlement should contain proposed findings and sanctions and be signed by the 

respondent or potential respondent and submitted to the Disciplinary Panel presiding over the matter.

c) A respondent or potential respondent may offer to settle disciplinary proceedings without admitting or 

denying the findings contained in the order of the disciplinary proceedings but must accept the 

jurisdiction of the SEF over it and over the subject matter of the proceedings and consent to the entry 

of the findings and sanctions imposed.

d) If a respondent or potential respondent submits an offer of settlement in accordance with paragraph (a) 

above, the Market Regulation Department will forward the offer to the Hearing Panel with a 

recommendation on whether to accept or reject the offer. If the Market Regulation Department and 

Hearing Panel agree to accept the offer of settlement, then the offer of settlement shall be accepted. If 

applicable, the Hearing Panel’s decision must include a statement that the respondent has accepted 

the sanctions imposed without either admitting or denying the rule violations.

e) Upon accepting any offer of settlement, the Hearing Panel shall issue a written decision specifying the 

rule violations it has reason to believe were committed, including the basis or reasons for the panel’s 

conclusions, and any sanction to be imposed, which must include full customer restitution where 

customer harm is demonstrated.
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f) If an offer of settlement is accepted by the Hearing Panel, the respondent’s submission of the offer will 

be deemed to constitute a waiver of the right to notice, opportunity for a hearing and review and appeal 

under the SEF Rules.

g) If the offer of settlement is not accepted or is withdrawn by the respondent or potential respondent, the 

matter will proceed as if the offer had not been made and the offer and all documents relating to it will 

not become part of the record. Neither a respondent or potential respondent nor the Hearing Panel 

may use an unaccepted offer of settlement as an admission or in any other manner at a hearing of, or 

appeal from, disciplinary proceedings.

RULE 1008 RESPONDENT REVIEW OF EVIDENCE

a) Prior to the commencement of a hearing, each respondent will be given the opportunity to review all 

books, records, documents, papers, transcripts of testimony and other tangible evidence in the 

possession or under the control of the SEF that the Market Regulation Department will use to support 

the allegations and proposed sanctions in the notice of charges or which the chair of the Hearing Panel 

deems relevant to the disciplinary proceedings. Notwithstanding the foregoing, no respondent will have 

the right to review, and the SEF will have no obligation to disclose, any information protected by 

attorney-client privilege.

b) If any books, records, documents, papers, transcripts of testimony, or other tangible evidence contain 

information that could adversely affect the competitive position of the Person providing the information 

or if such information might compromise other investigations being conducted by the Market 

Regulation Department, the Market Regulation Department may redact, edit or code such information 

before furnishing it to the respondent.

c) Notwithstanding anything in paragraph (b) above to the contrary, the Market Regulation Department:

(1) will not redact, edit or code competitive or investigative information contained in documents in a 

manner that would impair the respondent’s ability to defend against the allegations or proposed 

sanctions in the notices of charges; and

(2) will provide the respondent with access to the information and portions of the documents that 

the Market Regulation Department intends to rely on to support the allegations or proposed 

sanctions in the notice of charges.

d) For purposes of this Rule 1008, information that could adversely affect competitive positions include 

positions in Contracts currently held, trading strategies employed in establishing or liquidating 

positions, the identity of any SEF Market Participant, and the personal finances of the Person providing 

the information.

RULE 1009 HEARINGS

Hearings shall be conducted pursuant to the procedures below.

a) Hearing Procedures

(1) A hearing shall be fair, shall be conducted before members of the disciplinary panel, and shall 

be promptly convened after reasonable notice to the respondent.

(2) If the respondent has requested a hearing, a copy of the hearing shall be made and shall 

become a part of the record of the proceeding. The record shall not be required to be 

transcribed unless:

i. The transcript is requested by CFTC staff or the respondent; or

ii. The decision is reviewed by the CFTC.in all other instances, a summary record of a 
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hearing will be prepared.

(3) After reasonable notice to each respondent, the Hearing Panel will promptly convene a hearing 

to conduct the disciplinary proceedings with respect to such respondent. Parties to a disciplinary 

proceeding include each respondent and the Market Regulation Department.

(4) The chair of the Hearing Panel may continue, adjourn or otherwise conduct the hearing, as he or 

she may deem appropriate. The chair of the Hearing Panel will determine all procedural and 

evidentiary matters, including the admissibility and relevance of any evidence proffered. In 

determining procedural and evidentiary matters, the chair of the Hearing Panel will not be bound 

by any evidentiary or procedural rules or law. Once admitted during the hearing, the Hearing 

Panel may consider, and attach the weight it believes appropriate to, evidence or othermaterials.

(5) Except for procedural and evidentiary matters decided by the chair of the Hearing Panel 

pursuant to paragraph (3), unless each respondent otherwise consents, the entire Hearing 

Panel must be present during the entire hearing and any related deliberations.

b) Conducting Hearings.

(1) At a hearing conducted in connection with any disciplinary proceedings, the Market Regulation 

Department will present its case supporting the allegations and proposed sanctions in the notice 

of charges to the Hearing Panel. If a respondent has timely filed an answer to the notice of 

charges in accordance with Rule 1006, the respondent is entitled to attend and participate in the 

hearing.

(2) At a hearing conducted in connection with any disciplinary proceedings, the Hearing Panel or 

the Market Regulation Department and each respondent may:

i. present evidence and facts determined relevant and admissible by the chair of the 

Hearing Panel;

ii. call and examine witnesses; and

iii. cross-examine witnesses called by other parties.

(3) If the respondent fails to file an answer, has filed a general denial, or if any or all of the 

allegations in the notice of charges are not expressly denied in the respondent’s answer, the 

chair of the Hearing Panel may limit evidence concerning any allegations not expressly denied 

in determining the sanctions to impose. If a respondent fails to file an answer but appears at the 

hearing, the respondent may not participate in the hearing (by calling or cross- examining 

witnesses, testifying in defense, presenting evidence concerning the notice of charges, or 

otherwise) unless the Hearing Panel determines that the respondent had a compelling reason 

for failing to timely file an answer. If the Hearing Panel determines that the respondent had a 

compelling reason for failing to timely file an answer, the Hearing Panel will adjourn the hearing 

and direct the respondent to promptly file a written answer in accordance with Rule 1006.

(4) Any Person entitled, or required or called upon, to attend a hearing before a Hearing Panel 

pursuant to paragraph (b)(2) above will be given reasonable notice, confirmed in writing, 

specifying the date, time and place of the hearing, and the caption of the disciplinary 

proceedings. All SEF Market Participants (that are individuals) that are called as witnesses are 

required to appear at the hearing and, where applicable, produce evidence. The Market 

Regulation Department will make reasonable efforts to secure the presence of all other Persons 

called as witnesses whose testimony would be relevant.

(5) If during any disciplinary proceeding, the Hearing Panel determines that a reasonable basis 

exists to believe that the respondent violated or is about to violate a Rule of the SEF or a 

provision of Applicable Law other than the violations alleged in the notice of charges, the 

Hearing Panel may consider those apparent violations after providing the respondent with an 

opportunity to answer the additional allegations in accordance with Rule 1006. In connection 

with considering apparent violations pursuant to this paragraph (b)(5), the Hearing Panel may 
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request that the Market Regulation Department provide the Hearing Panel with any additional 

information related to the violations at issue.

(6) The SEF will arrange for an audio recording of every hearing conducted in connection with 

disciplinary proceedings to be created, which shall become a part of the record. At the direction 

of the CFTC or the request of the respondent, the SEF will arrange for the recording to be 

accurately transcribed. If the respondent requests a copy of all or portions of the recording of a 

hearing, the chair of the Hearing Panel may within his or her sole discretion require the 

respondent to pay the costs for transcribing the recording of the hearing.

c) The Hearing Panel may summarily impose sanctions on any SEF Market Participant that impedes or 

delays the progress of a hearing.

d) No interlocutory appeals of rulings of any Hearing Panel or chair of the Hearing Panel are permitted.

RULE 1010 DECISION OF HEARING PANEL

The decision of the Hearing Panel shall be made pursuant to the procedures of the Regulatory Services 

Provider, if any, or through the procedures below.

a) As promptly as reasonable following a hearing, the Hearing Panel will issue a written order rendering 

its decision based on the weight of the evidence contained in the record of the disciplinary 

proceedings. A decision by a majority of the Hearing Panel will constitute the decision of the Hearing 

Panel.

b) The Chief Compliance Officer will serve a copy of the order of the disciplinary proceedings on the 

respondent and the Market Regulation Department. The order will include:

(1) the notice of charges or summary of the allegations;

(2) the answer, if any, or a summary of the answer;

(3) a brief summary of the evidence introduced at the hearing or, where appropriate, incorporation 

by reference of the Investigation Report;

(4) findings of fact and conclusions concerning each allegation, including a complete explanation of 

the evidentiary and other basis for such findings and conclusions with respect to each allegation;

(5) each specific Rule of the SEF and provision of Applicable Law that the respondent is found to 

have violated; and

(6) the imposition of sanctions, if any, including the basis for such sanctions and the effective date 

of each sanction.

c) The decision of a Hearing Panel will not become effective until at least 15 days after the written notice 

described in Rule 1010(b) is served on the respondent and a copy thereof is provided to the Market 

Regulation Department, except as provided for in CFTC Regulation 9.12.

RULE 1011 SANCTIONS

a) After notice and opportunity for hearing in accordance with the SEF Rules, the SEF will impose 

sanctions if any SEF Market Participant or other Person using the Participant’s Legal Entity Identifier is 

found to have violated or to have attempted to violate a Rule of the SEF or provision of Applicable Law 

for which the SEF possesses disciplinary jurisdiction. All sanctions, including sanctions imposed 

pursuant to an accepted settlement offer, shall be commensurate with the violations committed and 

shall be sufficient to deter recidivism or similar violations by other market participants, and must take 

into account the respondent’s disciplinary history. In the event of demonstrated customer harm, any 
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sanction must also include full customer restitution, except where the amount of restitution or to whom 

it should be provided cannot be reasonably determined. The SEF may impose one or more of the 

following sanctions or remedies: (1) censure; (2) limitation on Trading Privileges, ability to otherwise 

access the Platform, and/or other activities, functions or operations; (3) suspension of Trading 

Privileges and/or ability to otherwise access the Platform; (4) fine (subject to paragraph (b) below); (5) 

restitution or disgorgement; (6) termination of Trading Privileges and/or ability to otherwise access the 

Platform; or (7) any other sanction or remedy deemed to be appropriate.

b) The SEF may impose a fine for each violation of a Rule of the SEF or a provision of Applicable Law. If 

a fine or other amount is not paid within 30 days of the date that it becomes payable, then interest will 

accrue on the sum from the date that it became payable at the quoted prime rate plus three (3) 

percent. The SEF has sole discretion to select the bank on whose quotations to base the prime rate. 

Participant will be responsible for paying any fine or other amount imposed on, but not paid by, any of 

its Authorized Persons or Authorized Representatives.

RULE 1012 RIGHT TO APPEAL

An appeal of a suspension, expulsion, disciplinary or access denial action, or other adverse action, 

including summary actions (as such terms are defined in CFTC Regulation 9.2 as applicable), imposed by 

the SEF pursuant to the SEF Rules may be taken pursuant to Part 9 of the CFTC Regulations.

RULE 1013 SUMMARY FINES

a) The Chief Compliance Officer or Market Regulation Department may summarily impose a fine for 

violations of rules relating to:

(1) the timely submission of accurate records required for clearing or verifying each day’s 

transactions;

(2) the timely payments of dues, assessments, fees, costs, charges, fines or arbitration awards to 

the SEF, or customer restitution ordered by the SEF;

(3) the timely and accurate submissions to the SEF of notices, reports or other information required 

by the SEF Rules; or,

(4) the maintenance of any books and records required by the SEF Rules.

b) The Chief Compliance Officer or Market Regulation Department will give notice of any summary 

fine imposed pursuant to this Rule 1013 to each Participant subject thereto. Such notice shall 

include:

(1) the violations of the SEF Rules for which the fine is being imposed;

(2) the date of the violation for which the fine is being imposed; and,

(3) the amount of the fine.

c) In lieu of a summary fine, the Chief Compliance Officer may issue a warning letter for first-time 

violations or violators pursuant to Rule 1002(c), provided that no more than one warning letter may be 

issued per rolling 12-month period for the same violation by the same Person.

d) Any Person subject to a summary fine may challenge such summary fine by denying the charges and 

filing a request for a hearing pursuant to Rule 1006(c).

e) The SEF will set the amount of any fines imposed pursuant to this Rule 1013, with the maximum fine 

for each violation not to exceed $3,000. Summary imposition of fines pursuant to this Rule 1013 will 

not preclude the SEF from bringing any other action against the Participant (or any of its Account 
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Managers, Authorized Persons or Authorized Representatives). The following schedule lists the 

recommended summary fines that the Chief Compliance Officer or Market Regulation Department may 

impose:

Type of Violation Fine Per Occurrence (within a “rolling” 12-month period)

First Violation Second Violation Third Violation

Violations of rules relating to the timely submission of 

accurate records required for clearing or verifying each 

day’s transactions

$1000 $1,250 $2,000

Violations of rules relating to the timely payments of 

dues, assessments, fees, costs, charges, fines or 

arbitration awards to the SEF, or customer restitution 

ordered by the SEF

$1000 $1,250 $2,000

Violations of rules relating to the timely and accurate 

submissions to the SEF of notices, reports or other 

information required by the SEF Rules

$1000 $1,250 $2,000

Violations of rules relating to the maintenance of any 

books and records required by the SEF Rules

$1000 $1,250 $2,000

RULE 1014 EMERGENCY SUMMARY SUSPENSIONS 

AND OTHER SUMMARY ACTIONS

a) Notwithstanding anything in the SEF Rules to the contrary, the Chief Compliance Officer may, after 

consultation with the Market Regulation Department, if practicable, summarily suspend, revoke, limit, 

condition, restrict or qualify a SEF Market Participant’s Trading Privileges and/or ability to otherwise 

access the Platform; provided, however, that the Chief Compliance Officer may only summarily 

suspend a SEF Market Participant’s Trading Privileges or the trading privileges of any Participant’s 

Authorized Persons if the Chief Compliance Officer reasonably believes that:

(1) such Person is subject to statutory disqualification from registration as provided in CEA Section 

8a(2) or (3);

(2) such Person has failed to pay applicable dues, assessments, fees, costs, charges, fines or 

arbitration awards to the SEF, or customer restitution ordered by the SEF; or

(3) immediate action is necessary to protect the public or the best interests of the SEF. And

provided further that any decision to summarily suspend, revoke, limit, condition, restrict or 

qualify a SEF Market Participant’s Trading Privileges and/or ability to otherwise access the 

Platform shall be impartially enforced.

b) Whenever practicable, the SEF shall provide prior written notice to the party against whom any action 

in accordance with paragraph (a) shall be taken. If prior notice is not practicable, the SEF will give 

notice at the earliest possible opportunity to the respondent against whom the action is brought.

c) Any action taken in accordance with paragraph (a) will become final upon the expiration of 20 days 

after the notice of action is served on the respondent.

d) At the request of the SEF, a respondent against whom a summary action is brought pursuant to this 

Rule 1014 must provide books and records over which the respondent has access or control and must 

furnish information to, or appear or testify before, the SEF in connection with the enforcement of any 

Rule of the SEF.
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RULE 1015 RIGHTS AND RESPONSIBILITIES AFTER 

SUSPENSION OR TERMINATION

a) When a SEF Market Participant’s Trading Privileges and/or ability to otherwise access the Platform are 

suspended for a period of 12 months or less, none of its rights (including the right to hold oneself out to 

the public as a Participant, enter Orders into the Platform and receive Participant rates for fees, costs, 

and charges and deposit margin at Participant levels) will apply during the period of the suspension, 

except for the right of the Participant in question to assert claims against others as provided in the SEF 

Rules. Any such suspension will not affect the rights of creditors under the SEF Rules or relieve the 

SEF Market Participant in question of its, his or her obligations under the SEF Rules to perform any 

Contracts entered into before the suspension, or for any the SEF fees, costs, or charges incurred 

during the suspension. The SEF may discipline a suspended SEF Market Participant under this 

Chapter 10 for any violation of a Rule of the SEF or provision of Applicable Law committed by the SEF 

Market Participant before, during or after the suspension.

b) When a Participant’s Trading Privileges and/or ability to otherwise access the Platform are terminated, 

all of its related rights will terminate, except for the right of the Participant in question to assert claims 

against others, as provided in the SEF Rules. Any such termination will not affect the rights of creditors 

under the SEF Rules. A terminated Participant may only seek to be reinstated by applying for Trading 

Privileges pursuant to Rule 302.

c) The SEF will not consider the application of a terminated Participant if such Participant, as the case 

may be, continues to fail to appear at disciplinary proceedings without good cause or continues to 

impede the progress of disciplinary proceedings.

d) A suspended or terminated SEF Market Participant remains subject to the SEF Rules and the 

jurisdiction of the SEF for acts and omissions prior to the suspension of termination, and must 

cooperate in any inquiry, investigation, disciplinary proceeding, summary suspension or other 

summary action as if the suspended or terminated SEF Market Participant still had Trading Privileges 

or ability to otherwise access the Platform.

e) In the event of the suspension or revocation of a Participant’s Trading Privileges and/or ability to 

otherwise access the Platform, the SEF shall seek to facilitate the transfer of any Customer Accounts 

held by such Participant to other Participants with Trading Privileges and/or ability to otherwise access 

the Platform.

RULE 1016 NOTICE TO THE RESPONDENT, THE 

REGULATORY SERVICES PROVIDER AND 

THE PUBLIC

a) The SEF will provide written notice of disciplinary proceedings to the parties, the Regulatory Services 

Provider, and the CFTC to the extent such notice is required by the Regulatory Services Provider 

and/or the CFTC. Whenever a SEF decision, pursuant to which a disciplinary action or access denial 

action is to be imposed becomes final, the SEF shall, within thirty days thereafter, provide written 

notice of such action to the Person against whom the action was taken and to the CFTC pursuant to 

CFTC Regulation 9.11 in accordance with procedures established by the CFTC.

b) Any disciplinary or access denial action taken by the SEF will not become effective until at least 15 

days after the written notice described in Rule 1016(a) is delivered to the Person disciplined or denied 

access, except as provided for in CFTC Regulation 9.12.
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Chapter 11 Arbitration Rules

RULE 1101 DISPUTES SUBJECT TO ARBITRATION

a) Mandatory Arbitration of Disputes.

(1) It is contrary to the objectives and policy of the SEF for Participants to litigate SEF-related 

disputes. Participants must arbitrate all disputes between or among themselves, or against the 

SEF, that relate to or arise out of any transaction on or subject to the SEF Rules that are based 

upon facts and circumstances that occurred at a time when the parties were Participants. Such 

arbitrations will be conducted pursuant to the NFA Arbitration Program.

(2) Notwithstanding the foregoing, this Rule 1101 does not require an employee of a Participant to 

submit to arbitration any claim that includes allegations of a violation of federal, state or local 

employment discrimination, sexual harassment, wage payment or benefits laws.

b) [Reserved]

c) Permissive Arbitrations.

The following may be submitted for arbitration through the National Futures Association 

Arbitration Program:

(1) claims of a Customer, Client or Sponsored Person that is not a Participant against a Participant 

that relate to or arise out of any Transaction on or subject to the SEF Rules, including any 

disputes brought under Rule 922(a); and

(2) [Reserved]

(3) at the discretion of the Chief Compliance Officer, any claim involving the interests of the SEF, its 

Participants, their business relations or trading in general not otherwise arbitrable under these 

rules, provided the parties have consented to such arbitration.

d) Waiver of Any Objection to Jurisdiction.

Any Person who is not a Participant who submits a claim or grievance to arbitration or any Person 

who appeals any arbitration decision, or who takes any steps therein, shall be conclusively 

presumed to have voluntarily recognized and agreed to the jurisdiction of the NFA to hear and 

determine the claim or appeal.

RULE 1102 INITIATING AN ARBITRATION CLAIM

a) A claimant may initiate a claim by submitting the required documents and fees to the NFA Arbitration 

Program. A claimant shall provide notice of such arbitration claim to the SEF.

b) An arbitration arising from or in connection with the SEF Rules must be brought to arbitration through 

by the NFA Arbitration Program or another arbitration program permitted by the CFTC Regulations 

within two (2) years from the occurrence of the event giving rise to the dispute.

c) Each party to the dispute will bear its own costs and expenses in connection with any arbitration 

hereunder, as well as an equal share of the administrative fees and the fees of the arbitrator; provided, 

however, that the arbitrator will be entitled to include in any award a full reimbursement for the 

prevailing party’s costs and expenses, such party’s share of the administrative fees and the fees of the 

arbitrator, or any combination of any or all of the above. In the event that this Rule 1102 is held to be 

unenforceable in connection with any dispute, (i) exclusive jurisdiction for any such dispute will reside 
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in any state or federal court sitting in the New York, NY metropolitan area, (ii) the SEF and the 

Participant involved in the dispute will be presumed to have submitted to the personal jurisdiction of 

any such court, and (iii) an action to enforce any judgment or decision of such court may be brought in 

the same court or in any other court with jurisdiction or venue.
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Chapter 12 Miscellaneous

RULE 1201 SEF PERSONNEL: TRADING AND MISUSE 

OF MATERIAL, NON-PUBLIC INFORMATION

a) Except as provided by Rules 1201(b) and 1201(c), Officers and SEF employees are prohibited from:

(1) Trading, directly or indirectly, in any Commodity Interest traded on the SEF;

(2) Trading, directly or indirectly, in any related Commodity Interest;

(3) Trading, directly or indirectly, in a Commodity Interest traded on other Swap Execution Facilities 

or any designated contract markets, or cleared by a Derivatives Clearing Organizations if the 

Officer or employee has access to material, non-public information concerning such Commodity 

Interest; and

(4) Trading, directly or indirectly, in a Commodity Interest traded on or cleared by a linked exchange 

if the employee has access to material, non-public information concerning such commodity 

interest.

b) The Chief Compliance Officer may exempt, in whole or in part, an Officer or SEF employee from the 

prohibitions of Rule 1201(a), if such Officer or SEF employee applies in writing for an exemption and 

demonstrates to the satisfaction of the Chief Compliance Officer that the Officer or SEF employee 

meets all of the following criteria:

(1) the Officer or SEF employee does not have access to material, non-public information in the 

course of his or her employment;

(2) the Officer or SEF employee agrees to provide the SEF with account statements and other 

documents relevant to the Officer’s or SEF employee’s buying and selling of Contracts directly 

or indirectly; and

(3) the Officer or SEF employee agrees to inform the Chief Compliance Officer in writing of any 

material change that may affect the Officer’s or SEF employee’s qualification for an exemption 

within one (1) Business Day of the change.

c) With the Chief Compliance Officer’s written approval, Rule 1201(a) does not prohibit an Officer or SEF 

employee from participating in a pooled investment vehicle or other investment vehicle whose 

investments are directed by a third-party advisor if the Officer or SEF employee has no direct or 

indirect control over transactions executed by the investment vehicles.

d) SEF Officials, employees, agents and independent contractors of the SEF are prohibited from 

disclosing material, non-public information obtained as a result of his or her employment, agency 

relationship or engagement with the SEF where the SEF Official, agent or independent contractor 

expected or should have reasonably expected that the information disclosed may assist a Person in 

trading any Contract, any Contract traded on another exchange, or any related underlying commodity 

or security.

e) Rule 1201(d) shall not prohibit a SEF Official, agent or independent contractor of the SEF from 

disclosing material, non-public information while discharging his or her official duties and 

responsibilities, including disclosures to another Self-Regulatory Organization, linked exchange, court 

of competent jurisdiction, or a representative of any agency or department of the federal or state 

government.
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f) For the purposes of this Rule 1201, the terms “material information,” “non-public information,” “linked 

exchange,” and “pooled investment vehicle” each shall have the meaning set forth in CFTC Regulation 

§ 1.59(a), or any successor regulation thereto.

RULE 1202 NO ENDORSEMENT OF OPINIONS, 

RESEARCH OR RECOMMENDATIONS

Any opinions, research or recommendations appearing on the Platform are not the SEF’s opinions, 

research or recommendations, and the SEF does not endorse them or any content provided by third 

parties.

RULE 1203 NOT A PARTY

The SEF is not directly or indirectly a party to or participant in any trade or Swap executed on or pursuant to 

the rules of the SEF.

RULE 1204 NO ADVICE

The SEF is not providing and shall not provide any financial, legal, tax, advisory, consultative or business 

services to Participant, or advice on structuring transactions or drafting or negotiating transaction 

documentation. Participant should seek its own legal, tax, financial and other advice when structuring, 

negotiating and/or documenting transactions.

RULE 1205 GIFTS AND GRATUITIES

Except as permitted in writing by the Chief Executive Officer, no Participant shall, directly or indirectly, give 

or permit to be given anything of value, including gifts and gratuities, in excess of one hundred dollars 

($100) per individual per year to a SEF Official or employee.

RULE 1206 MARKET DATA AND INTELLECTUAL 

PROPERTY 

a) Subject to each Participant's rights in Participant’s own data as set forth in the Participant 

Documentation, the SEF shall have a non-exclusive, royalty free, worldwide, perpetual license to any 

Participant’s Transaction Data, to use, distribute, or disclose for the benefit of the SEF and shall own 

all rights, title and interest in and to all intellectual property and other proprietary rights (including all 

copyright, patent, trademark or trade secret rights) in all derivative works based on Transaction Data to 

the extent that such derived data is truly a derivative of the Transaction Data.

b) Participant shall not, without the SEF’s prior written consent, directly or indirectly, sell, redistribute, or 

facilitate redistribution of, all or any portion of the Transaction Data to any third party; provided, 

however, that such consent shall not be required for (i) redistributing, or facilitating the redistribution of 

Transaction Data, (ii) copying, reproduction or re-transmission of information that is generally available 

to the public free of charge, (iii) use of any part of the data on the Platform for administrative, 

regulatory or reporting purposes of the Participant, (iv) the solicitation and entry of orders for trades on 

the Platform, or (v) the provision of indicative valuations to Participant’s counterparties.
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c) Notwithstanding Rule 1206(b), any Transaction Data that Participant generates and provides to the 

SEF in connection with Transactions shall be treated as the non-exclusive property of Participant and 

the SEF, each of whom shall have the right to use, sell, retransmit and/or redistribute such Transaction 

Data; provided, however, that the SEF shall not use (or permit other parties to use) Transaction Data 

to replicate or reverse engineer Participant’s trading strategies and shall not sell, retransmit or 

redistribute Transaction Data unless such Transaction Data is anonymized, except in each case as 

required by Applicable Law and/or any agreements that the SEF has entered into with Derivatives 

Clearing Organization(s).

d) The SEF will not use for business or marketing purposes any Proprietary Data or Personal Information 

collected or received from or on behalf of any Person for the purpose of fulfilling the SEF’s regulatory 

obligations.

e) The SEF may share Proprietary Data or Personal Information with one or more Swap Execution 

Facilities, designated contract markets, or the CFTC for regulatory purposes in accordance with 

Applicable Law.

f) Each Participant, and other Persons affiliated with the Participant hereby acknowledges and agrees 

that the SEF may disclose and disseminate Creation Data pursuant to these Rules.

g) Each Participant, and other Persons affiliated with any of the foregoing hereby acknowledges and 

agrees that the SEF owns and shall retain all right, title and interest in and to the SEF, all components 

thereof, including without limitation all related applications, all application programming interfaces, user 

interface designs, software and source code and any and all intellectual property rights therein, 

including, without limitation all registered or unregistered, as applicable copyright, trade mark, service 

mark, trade secret, trade name, data or database rights, design rights, moral rights, inventions, 

whether or not capable or protection by patent or registration, rights in commercial information or 

technical information, including know-how, research and development data and manufacturing 

methods, patent, and other intellectual property and ownership rights, including applications for the 

grant of any of the same, in or to the SEF and all other related proprietary rights of the SEF and/or any 

of its affiliates (together, with any and all enhancements, corrections, bug fixes, updates and other 

modifications to any of the foregoing and any and all data or information of any kind transmitted by 

means of any of the foregoing, “Proprietary Information”). Each Participant, on behalf of itself and each 

of its affiliates and other Persons affiliated with any of the foregoing, further acknowledges and agrees 

that the Proprietary Information is the exclusive, valuable and confidential property of the SEF. Each 

Participant acknowledges and agrees that it shall not, and shall not permit its affiliates and other 

Persons affiliated with any of the foregoing to, reverse engineer, copy, bug fix, correct, update, 

transfer, reproduce, republish, broadcast, create derivative works based on or otherwise modify, in any 

manner, all or any part of the SEF or the Proprietary Information. Each Participant further agrees to, 

and agrees to cause each of its affiliates and other Persons affiliated with any of the foregoing to, keep 

the Proprietary Information confidential and not to transfer, rent, lease, loan, sell or distribute, directly 

or indirectly, all or any portion of the SEF or any Proprietary Information.

RULE 1207 EXTENSION OR WAIVER OF RULES

If necessary and expedient, the SEF may, in its sole discretion, waive, or extend the time period for 

performing, any act or acts designated by the SEF Rules, but only to the extent such waiver or extension is 

not inconsistent with the CEA or the CFTC Regulations.
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RULE 1208 EFFECT OF AMENDMENT, REPEAL OR 

NEW RULE

a) These SEF Rules may be modified or amended by the SEF by posting such amendments to the SEF 

website, and any such amendment shall be applicable to and binding and shall be effective when 

posted.

b) If an amendment or repeal of a SEF Rule or adoption of a new SEF Rule does not materially change 

the terms or conditions of a Contract and does not affect the value of open Contracts as determined by 

the Board in its sole discretion, then the effective date of any amendment or repeal of a SEF Rule or 

adoption of a new SEF Rule relating to Contracts is binding on all Contracts entered into before and 

after the effective date of such amendment, repeal or adoption.

c) If an amendment or repeal of a SEF Rule or adoption of a new SEF Rule materially changes the terms 

or conditions of a Contract or affects the value of open Contracts as determined by the Board in its 

sole discretion, then the amendment, repeal or new SEF Rule is binding only on Contracts listed for 

trading after the effective date of such amendment, repeal or adoption, and Contracts listed as of the 

effective date of such amendment, repeal or adoption with no open positions then in existence, unless 

otherwise specifically provided by the Board.

RULE 1209 ANTITRUST CONSIDERATIONS

Neither the SEF nor its Directors, Officers or employees may take any action that results in an 

unreasonable restraint of trade or imposes any anticompetitive burden on trading or clearing.

RULE 1210 GOVERNING LAW, JURISDICTION AND 

DISPUTE RESOLUTION

a) The law of the State of New York governs the SEF Rules.

b) Any dispute between the SEF and a Participant arising from or in connection with the SEF Rules will 

be settled by arbitration pursuant to Chapter 11. All Participants unconditionally and irrevocably waive 

any and all right to trial by jury in connection with any such dispute.
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Chapter 13 Contract Terms and 

Conditions

RULE 1301 NON-DELIVERABLE FORWARDS

NDF Contract Terms

Contract Overview A non-deliverable forward (NDF) is an outright forward contract in which counterparties 

settle the difference between the contracted NDF price or rate and the prevailing spot 

price or rate on an agreed notional amount, and where settlement is performed in USD.

Reference Currency 1 &

Reference Currency 2

Non Deliverable Currencies

AFN Afghan Afghani 

ALL Albanian Lek

ANG Netherlands Antillean Guilder 

AOA Angolan Kwanza

ARS Argentine Peso 

AWG Aruban Florin

AZN Azerbaijanian Manat

BAM Bosnia-Herzegovina Convertible Mark 

BMD Bermudan Dollar

BOB Bolivian Boliviano 

BRL Brazilian Real BYN Belarus Ruble 

CDF Congolese Franc 

CLP Chilean Peso

CNY Chinese Renminbi

COP Colombian Peso

CVE Cape Verde Islands Escudo

DJF Djibouti Franc

EGP Egyptian Pound 

ERN Eritrean Nakfa 

GMD Gambia Dalasi

GTQ Guatemalan Quetzal 

GYD Guyana Dollar

HTG Haitian Gourde 

IDR Indonesian Rupiah 

INR Indian Rupee

IQD Iraqi Dinar 

KES Kenya Shilling

KGS Kyrgyzstan Som 

KHR Cambodian Riel 

KMF Comoros Franc 

KRW South Korean Won

KYD Cayman Islands Dollar 

KZT Kazakh Tenge

LAK Lao Kip

LRD Liberian Dollar 

LSL Lesotho Loti 

LYD Libyan Dinar 

MMK Myanmar Kyat

MNT Mongolian Tugrik 

MOP Macau Pataca 

MRO Mauritania Ouguiya 

MVR Maldives Rufiyaa 
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NDF Contract Terms

MYR Malaysian Ringgit

MZN Mozambique Metical 

NPR Nepali Rupee

PEN Peruvian Nuevo 

Sol PHP Philippine Peso 

PKR Pakistan Rupee 

RUB Russian Ruble 

SCR Seychelles Rupee 

SLL Sierra Leone Leone 

SRD Suriname Dollar 

SSP South Sudan Pound 

THB Thai Baht

TJS Tajikistani Somoni

TMT Turkmenistan New Manat 

TWD Taiwan Dollar

UAH Ukrainian Hryvnia 

UYU Uruguayan Peso 

VEF Venezuelan Bolívar 

VND Vietnamese Dong 

VUV Vanuatu Vatu

XPF CPF Franc

YER Yemeni Rial

ZMW Zambian Kawacha

Deliverable Currencies

AED United Arab Emirates 

Dirham AUD Australia Dollar

BGN Bulgaria Lev 

BHD Bahraini Dinar 

BWP Botswana Pula 

CAD Canada Dollar 

CHF Switzerland Franc

CNH Offshore Chinese Renminbi 

CZK Czech Republic Koruna 

DKK Denmark Krone

EEK Estonia Kroon 

EUR Euros

GBP United Kingdom Pound 

HKD Hong Kong Dollar

HRK Croatia Kuna 

HUF Hungary Forint 

ILS Israel Shekel 

ISK Iceland Krona 

JMD Jamaica Dollar 

JOD Jordan Dinar 

JPY Japan Yen 

KWD Kuwait Dinar

LKR Sri Lanka Rupee 

LVL Latvia Lats

MAS Morocco Dirham

MUR Mauritius Rupee 

MXN Mexico Peso 

NOK Norway Krone

NZD New Zealand Dollar 

OMR Oman Rial

PLN Poland Zloty 

QAR Qatar Riyal

RON Romania New Leu 
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NDF Contract Terms

RSD Serbia Dollar

SAR Saudi Arabia Riyal 

SEK Sweden Krona 

SGD Singapore Dollar 

SKK Slovakia Koruna 

TND Tunisia Dollar 

TOP Tonga Pa’anga 

TRY Turkey Lira

USD U.S. Dollar

WST Western Samoan Tala 

XOF West African CFA Franc 

ZAR South Africa Rand

ZWD Zimbabwe Dollar

Settlement Currency Non-deliverable forwards (NDFs) settle in USD

Quoting Convention and 

Minimum Increment

Notional amount, as agreed by the counterparties

Minimum Size Notional amount, as agreed by the counterparties

Notional Currency Currency in which the contract size is expressed in

Trading Conventions Buy or Sell which refers to the contract size expressed in notional currency

Forward Rate Currency exchange rate expressed as the amount of reference currency per unit of nonreference currency

Trade Date The date on which parties enter into the contract

Settlement Date Specified settlement or payment date

Fixing Date The date at which the forward rate is calculated

Settlement Procedure Bilateral settlement performed in the Settlement Currency

Trading Hours 13:00 Sunday - 17:00 Friday Eastern Time

Clearing Venue Bilateral

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

Speculative Limits As set forth in CFTC 17 CFR Part 150

Reportable Levels As set forth in CFTC Regulation 15.03

Spot FX Rate Calculation

For NDFs consisting of a Deliverable and Non-Deliverable Currency as Reference Currencies, the Spot FX 

Rate will be derived from a combination of (1) the spot rate identified in the relevant EMTA, Inc. (“EMTA”) 

Template for the applicable Non-Deliverable Currency assuming USD as the Settlement Currency (the 

“Non-Deliverable Spot Rate”), and (2) the WM/Reuters 4:00 pm Closing Spot Rate for the applicable 

Deliverable Currency against USD; provided, however, that if the WM/Reuters Closing Spot Rate is quoted 

in units to a non-USD currency, then the Closing Spot Rate shall be converted to USD in accordance with 

Section 6 of the WM/Reuters Spot & Forward Rates Methodology Guide, as amended and supplemented 

from time to time, or any successor thereto. The Non-Deliverable Spot Rate shall incorporate all of the 
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EMTA template terms then in effect as recommended by EMTA or a recognized successor that are 

applicable to the Non-Deliverable Currency (assuming USD as the Settlement Currency).

For NDFs consisting of two Non-Deliverable Currencies as Reference Currencies, the Spot FX Rate will be 

derived from a combination of the Non-Deliverable Spot Rate for each of the applicable Non-Deliverable 

Currencies, assuming USD as the Settlement Currency. The Non-Deliverable Spot Rates shall incorporate 

all of the EMTA template terms then in effect as recommended by EMTA or a recognized successor that 

are applicable to the Non-Deliverable Component Pair (assuming USD as the Settlement Currency).

For NDFs consisting of two Deliverable Currencies as Reference Currencies, the Spot FX Rate will be 

derived from a combination of the WM/Reuters 4:00 pm Closing Spot Rate for both of the applicable 

Deliverable Currencies against USD; provided, however, that if the WM/Reuters Closing Spot Rate for one 

or both Deliverable Currencies is quoted in units to a non-USD currency, then the Closing Spot Rate for 

such currency or currencies shall be converted to USD in accordance with Section 6 of the WM/Reuters 

Spot & Forward Rates Methodology Guide, as amended and supplemented from time to time, or any 

successor thereto.

RULE 1302 CROSS-CURRENCY NDF xxx 

Cross-Currency NDF Contract Terms

Contract Overview A cross-currency non-deliverable forward (“NDF”) is an outright

forward contract in which counterparties settle the difference between the contracted 

NDF price or rate and the prevailing spot price or rate on an agreed notional amount, 

and where settlement may be performed in certain currencies other than USD.

Reference Currency 1 &

Reference Currency 2

Non Deliverable Currencies

ARS Argentine Peso 

BRL Brazilian Real 

CLP Chilean Peso

CNY Chinese Renminbi 

COP Colombian Peso 

EGP Egyptian Pound 

GTQ Guatemalan Quetzal 

IDR Indonesian Rupiah 

INR Indian Rupee

KES Kenya Shilling 

KRW South Korean Won 

KZT Kazakh Tenge 

MYR Malaysian Ringgit

PEN Peruvian Nuevo Sol 

PHP Philippine Peso 

PKR Pakistan Rupee 

RUB Russian Ruble

THB Thai Baht 

TWD Taiwan Dollar

UAH Ukrainian Hryvnia 

UYU Uruguayan Peso 

VEF Venezuelan Bolívar 

VND Vietnamese Dong

Deliverable Currencies

AED United Arab Emirates Dirham

AUD Australia Dollar 

BGN Bulgaria Lev 

BWP Botswana Pula 

CAD Canada Dollar 
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Cross-Currency NDF Contract Terms

CHF Switzerland Franc

CNH Offshore Chinese Renminbi 

CZK Czech Republic Koruna 

DKK Denmark Krone

EEK Estonia Kroon

EUR Euros

GBP United Kingdom Pound 

HKD Hong Kong Dollar

HRK Croatia Kuna 

HUF Hungary Forint 

ILS Israel Shekel 

ISK Iceland Krona 

JMD Jamaica Dollar 

JOD Jordan Dinar 

JPY Japan Yen 

KWD Kuwait Dinar

LKR Sri Lanka Rupee 

LVL Latvia Lats

MAS Morocco Dirham 

MUR Mauritius Rupee 

MXN Mexico Peso 

NOK Norway Krone

NZD New Zealand Dollar 

OMR Oman Rial

PLN Poland Zloty 

QAR Qatar Riyal

RON Romania New Leu 

RSD Serbia Dollar

SAR Saudi Arabia Riyal 

SEK Sweden Krona 

SGD Singapore Dollar 

SKK Slovakia Koruna 

TND Tunisia Dollar 

TRY Turkey Lira

USD U.S. Dollar

XOF West African CFA Franc 

ZAR South Africa Rand

ZWD Zimbabwe Dollar

Settlement Currency AUD Australia Dollar 

CAD Canada Dollar 

CHF Switzerland Franc 

DKK Denmark Krone 

EUR Euros

GBP United Kingdom Pound 

HKD Hong Kong Dollar

JPY Japan Yen 

MXN Mexico Peso 

NOK Norway Krone

NZD New Zealand Dollar 

PLN Poland Zloty

SEK Sweden Krona 

SGD Singapore Dollar

ZAR South Africa Rand

BRL Brazilian Real 

CNY Chinese Renminbi 

INR Indian Rupee
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Cross-Currency NDF Contract Terms

KES Kenya Shilling 

KZT Kazakh Tenge 

PKR Pakistan Rupee

Quoting Convention and 

Minimum Increment

Notional amount, as agreed by the counterparties

Minimum Size Notional amount, as agreed by the counterparties

Notional Currency Currency in which the contract size is expressed in

Trading Conventions Buy or Sell which refers to the contract size expressed in Notional Currency

Forward Rate Currency exchange rate expressed as the amount of Reference Currency 1 per unit of 

Reference Currency 2 per unit of Settlement.

Trade Date The date on which parties enter into the contract

Settlement Date Specified settlement or payment date

Fixing Date The date at which the forward rate is calculated

Settlement Procedure Bilateral settlement performed in the Settlement Currency

Trading Hours 13:00 Sunday - 17:00 Friday Eastern Time

Clearing Venue Bilateral

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

Speculative Limits As set forth in CFTC 17 CFR Part 150

Reportable Levels As set forth in CFTC Regulation 15.03

Spot FX Rate Calculation

For Cross-Currency NDFs consisting of a Deliverable and Non-Deliverable Currency as Reference 

Currencies, a base exchange rate, expressed in USD (the “Base Exchange Rate”) will be derived from a 

combination of (1) the spot rate identified in the relevant EMTA, Inc. (“EMTA”) Template for the applicable 

Non-Deliverable Currency assuming USD as the Settlement Currency (the “Non- Deliverable Spot Rate”), 

and (2) the WM/Reuters 4:00 pm Closing Spot Rate for the applicable Deliverable Currency against USD; 

provided, however, that if the WM/Reuters Closing Spot Rate is quoted in units to a non-USD currency, 

then the Closing Spot Rate shall be converted to USD in accordance with Section 6 of the WM/Reuters 

Spot & Forward Rates Methodology Guide, as amended and supplemented from time to time, or any 

successor thereto. The Non-Deliverable Spot Rate shall incorporate all of the EMTA template terms then in 

effect as recommended by EMTA or a recognized successor that are applicable to the Non-Deliverable 

Currency (assuming USD as the Settlement Currency). The Spot FX Rate will then be derived from the 

WM/Reuters 4:00 pm Closing Spot Rate for the Settlement Currency against the Base Exchange Rate; 

provided, however, that if the WM/Reuters Closing

Spot Rate is quoted in units to a non-USD currency, then the Closing Spot Rate shall be converted to USD 

in accordance with Section 6 of the WM/Reuters Spot & Forward Rates Methodology Guide, as amended 

and supplemented from time to time, or any successor thereto.

For Cross-Currency NDFs consisting of two Non-Deliverable Currencies as Reference Currencies, the 

Base Exchange Rate will be derived from a combination of the Non-Deliverable Spot Rate for each of the 
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applicable Non-Deliverable Currencies, assuming USD as the Settlement Currency. The Base Exchange 

Rate shall incorporate all of the EMTA template terms then in effect as recommended by EMTA or a 

recognized successor that are applicable to the Non-Deliverable Component Pair (assuming USD as the 

Settlement Currency). The Spot FX Rate will then be derived from the WM/Reuters 4:00 pm Closing Spot 

Rate for the Settlement Currency against the Base Exchange Rate; provided, however, that if the 

WM/Reuters Closing Spot Rate is quoted in units to a non-USD currency, then the Closing Spot Rate shall 

be converted to USD in accordance with Section 6 of the WM/Reuters Spot & Forward Rates Methodology 

Guide, as amended and supplemented from time to time, or any successor thereto.

For Cross-Currency NDFs consisting of two Deliverable Currencies as Reference Currencies, the Base 

Exchange Rate will be derived from a combination of the WM/Reuters 4:00 pm Closing Spot Rate for both 

of the applicable Deliverable Currencies against USD; provided, however, that if the WM/Reuters Closing 

Spot Rate for one or both Deliverable Currencies is quoted in units to a non-USD currency, then the 

Closing Spot Rate for such currency or currencies shall be converted to USD in accordance with Section 6 

of the WM/Reuters Spot & Forward Rates Methodology Guide, as amended and supplemented from time to 

time, or any successor thereto. The Spot FX Rate will then be derived from the WM/Reuters 4:00 pm 

Closing Spot Rate for the Settlement Currency against the Base Exchange Rate; provided, however, that if 

the WM/Reuters Closing Spot Rate is quoted in units to a non- USD currency, then the Closing Spot Rate 

shall be converted to USD in accordance with Section 6 of the WM/Reuters Spot & Forward Rates 

Methodology Guide, as amended and supplemented from time to time, or any successor thereto.

RULE 1303 FX OPTIONS

FX Option Contract Terms

Contract Overview A Foreign Exchange Option (FX option) is a derivative financial instrument that gives 

the buyer the right, but not the obligation, to buy or sell a specific quantity of one 

foreign currency in exchange for another currency at a pre-arranged fixed price on a 

specific date.

Trade Date The date on which the parties enter into the contract

Option Style European – a European option may only be exercised at the expiration date of the 

option.

Option Type Call option – the right to purchase a currency pair at a given exchange rate in the 

future.

Put option – the right to sell a currency pair at a given exchange rate in the future.

Call Currency Currency for a call option

Put currency Currency for a put option

Expiration Date Date at which the option contract expires

Expiration Time Time at which the option contract expires

Settlement Date Settlement date of the option contract

Premium Amount expressed in premium currency

Premium Date Date on which the premium is due

Quoting Convention and 

Minimum Increment

Notional amount, as agreed by the counterparties

Minimum Size Notional amount, as agreed by the counterparties
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FX Option Contract Terms

Notional Currency Currency in which the contract size is expressed in

Settlement Procedure Bilateral settlement performed in the settlement currency

Trading Hours 13:00 Sunday - 17:00 Friday Eastern Time

Clearing Venue Bilateral

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

Speculative Limits As set forth in CFTC 17 CFR Part 151

Reportable Levels As set forth in CFTC Regulation 15.03
Appendix A Appropriate Minimum Block Sizes

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Appendix A Appropriate Minimum 

Block Sizes

The appropriate minimum block sizes for foreign exchange swaps set forth by the CFTC in Appendix F to 

Part 43 of the CFTC Regulations, as of November 16, 2015, are reproduced below.

Super-major currencies

EUR

(Euro)

GBP

(British pound)

JPY

(Japanese yen)

USD

(U.S. dollar)

Super-major currencies EUR 6,250,000 6,250,000 18,750,000

GBP *6,250,000 6,250,000 6,250,000

JPY *6,250,000 *6,250,000 1,875,000,000

USD *18,750,000 *6,250,000 *1,875,000,000

Major currencies AUD *6,250,000 0 10,000,000 10,000,000

CAD *6,250,000 0 10,000,000 10,000,000

CHF *6,250,000 *6,250,000 12,500,000 12,500,000

DKK 0 0 0 0

KRW 0 0 0 6,250,000,000

SEK *6,250,000 0 0 100,000,000

NOK *6,250,000 0 0 100,000,000

NZD 0 0 0 5,000,000

ZAR 0 0 0 25,000,000

Non-major currencies BRL 0 0 0 5,000,000

CZK 200,000,000 0 0 200,000,000

HUF 1,500,000,000 0 0 1,500,000,000

ILS 0 0 0 50,000,000

MXN 0 0 0 50,000,000

PLN 25,000,000 0 0 25,000,000

RMB 50,000,000 0 50,000,000 50,000,000

RUB 0 0 0 125,000,000

TRY *6,250,000 0 0 *10,000,000

All values that do not have an asterisk are denominated in the currency of the left-hand side.

All values that have an asterisk (*) are denominated in the currency indicated on the top of the table.
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