SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 23-011

Organization: NEX SEF Limited ("NEX SEF")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 01/05/23 Filing Description: Initial Listing of the Euro/Swiss 

Franc (EUR/CHF) Option Contract

SPECIFY FILING TYPE 

Please note only ONE choice allowed per Submission.

Organization Rules and Rule Amendments

Certification § 40.6(a)

Approval § 40.5(a)

Notification § 40.6(d)

Advance Notice of SIDCO Rule Change § 40.10(a)

SIDCO Emergency Rule Change § 40.10(h)

Rule Numbers: 

New Product Please note only ONE product per Submission.

Certification § 40.2(a) 

Certification Security Futures § 41.23(a)

Certification Swap Class § 40.2(d)

Approval § 40.3(a)

Approval Security Futures § 41.23(b)

Novel Derivative Product Notification § 40.12(a)

Swap Submission § 39.5

Product Terms and Conditions (product related Rules and Rule Amendments)

Certification § 40.6(a) 

Certification Made Available to Trade Determination § 40.6(a)

Certification Security Futures § 41.24(a)

Delisting (No Open Interest) § 40.6(a) 

Approval § 40.5(a)

Approval Made Available to Trade Determination § 40.5(a)

Approval Security Futures § 41.24(c)

Approval Amendments to enumerated agricultural products § 40.4(a), § 40.5(a)

“Non-Material Agricultural Rule Change” § 40.4(b)(5)

Notification § 40.6(d)

Official Name(s) of Product(s) Affected: 

Rule Numbers:
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

1

Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

January 5, 2023

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Re: CFTC Regulation 40.2(a) Certification. Initial Listing of the Euro/Swiss Franc 

(EUR/CHF) Option Contract.

NEX SEF Submission No. 23-011

Dear Mr. Kirkpatrick:

NEX SEF Limited (“NEX SEF”), a registered Swap Execution Facility (“SEF”), is certifying to the Commodity 

Futures Trading Commission (“CFTC” or “Commission”) the initial listing of the Euro/Swiss Franc (EUR/CHF) 

Option (the “Contract”) for trading effective on January 9, 2023.

Specifically, NEX SEF is adopting amendments to Rule 803 (“Foreign Exchange Options”) to facilitate the listing 

the Contract for trading. Exhibit A below sets forth Rule 803 with additions underscored.

NEX SEF reviewed the SEF core principles (“Core Principles”) as set forth in the Commodity Exchange Act 

(“CEA” or “Act”) and identified that listing the Contracts may have some bearing on the following Core Principles:

• Compliance with Rules: Trading in the Contract will be subject to all NEX SEF Rules, 

including the rules on trading procedures set forth in Chapter 3 of its rulebook, the 

prohibitions against fraudulent, noncompetitive, unfair and abusive practices as outlined in 

Chapter 4 of its rulebook, and the dispute resolution and arbitration procedures of Chapter 

5 of its rulebook. As with all products listed for trading on NEX SEF, trading activity in the 

Contracts will be subject to monitoring and surveillance by NEX SEF’s market regulation 

staff, which has the authority to exercise its investigatory and enforcement power where 

potential rule violations are identified.

• Swaps Not Readily Subject to Manipulation: The Contract is not readily subject to 

manipulation because of the underlying market and reliance on a well administered index. 

• Monitoring of Trading and Trade Processing: Trading in the Contract will be subject to the 

NEX SEF rules (“Rulebook”) which include prohibitions on manipulation and price distortion. 

• Ability to Obtain Information: NEX SEF will publish on its website information in regard to 

contract specifications, terms, and conditions, as well as daily trading volume and price 

information for the Contracts. In addition, NEX SEF will advise the marketplace of the launch 

of the Contracts by releasing a notice to its participants.

• Timely Publication of Trading Information: NEX SEF will publish contract trading volumes 

and price information daily on its website.
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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• Recordkeeping and Reporting: All required trade information is included in the audit trail 

and is sufficient for the Market Regulation Department to monitor for market abuse.

Pursuant to Section 5c(c) of the Act and CFTC Regulation 40.2(a), NEX SEF hereby certifies that listing the 

Contract complies with the Act, including regulations under the Act. There were no substantive opposing views 

to the proposal. 

NEX SEF certifies that this submission has been concurrently posted on its website at 

http://www.cmegroup.com/market-regulation/rule-filings.html.

Should you have any questions concerning the above, please contact the undersigned at 212-299-2200 or 

CMEGSubmissionInquiry@cmegroup.com.

 

Sincerely,

 /s/ Christopher Bowen

 Managing Director and Chief Regulatory Counsel

Attachment: Exhibit A: NEX SEF Rulebook - Rule 803 (blackline format)
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Exhibit A

NEX SEF Rulebook

(additions underscored)

****

Products — Rule 803:

(1) Foreign Exchange Options (FX Options)

Contract 

Specification

Details

Product Description FX Option: a transaction in which the buyer has the right, but not the obligation, 

to buy (call option) or sell (put option) a fixed amount of foreign exchange at a 

fixed exchange rate agreed by the parties for a specified time period.

Reference & 

Settlement 

Currencies Reference 

Currency

Counter 

Currency

Settlement 

Currency

Units of 

Trading

EUR USD USD EUR

GBP USD USD GBP

EUR GBP GBP EUR

USD JPY USD USD

EUR JPY EUR EUR

USD CHF USD USD

USD CAD CAD USD

AUD USD AUD AUD

USD MXN USD USD

USD CNH USD USD

USD INR USD USD

USD SGD USD USD

NZD USD NZD NZD

USD HKD USD USD

BRL USD USD USD

MXN USD USD USD

USD ZAR USD USD

EUR SEK EUR EUR

EUR CHF EUR EUR

Notional Amount As agreed by the parties

Option Style American and European

Option Premium As agreed by the parties

Premium Payment Spot date relative to option trade date

Trading Hours 24 Hours, beginning at 6:00 a.m. Wellington Time on Monday (5:00 p.m. UTC on 

Sunday during NZDT/6:00 p.m. UTC on Sunday during NZST) and ending at 

5:00 p.m. New York Time on Friday (10:00 p.m. UTC during EST/9:00 p.m. UTC 

during EDT)

Quotation The price quotation is determined as a decimal number with up to five decimal 

places 
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Units of Trading See current currency list above. 

Expiration Date and 

Time

As agreed by the parties

Settlement Terms Bilateral settlement performed in Settlement Currency 

Settlement Date Settlement Date – Spot date relative to Expiration Date (if option is exercised)

Minimum Price 

Fluctuation/Price 

Tick Size

The minimum price change is 0.0001

Settlement Price N/A

Strike Prices As agreed by the parties

Contract Size As agreed by the parties

Maturity Date As agreed by the parties

Exercise Manual. Exercise decision is determined by the buyer of the option.

Last Trading Day / 

Time

Not Applicable

Trading 

Conventions

a. Buyer of the option has the right, but not the obligation to buy (call 

option) or sell (put option) the Reference Currency 

b. Seller of the option must sell (call) or buy (put) the Reference Currency if 

exercised by the option buyer

Block Size 1 million notional units of Reference Currency; 2 million units minimum trade 

size

Position Limits Not Applicable

Reportable Levels All FX Option trades are reported

Clearing FX Options are not cleared