311373478 

 Plaza 5, 185 Hudson St #2200 

Jersey City, NJ 07311 

February 2, 2022

Submitted via CFTC Portal 

Mr. Christopher J. Kirkpatrick 

Office of the Secretariat 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, D.C. 20581 

Re: DW SEF LLC – Amendment of Rule 205 (Regulatory Oversight Committee) and Rule 

 901 (Swap Specifications) 

Dear Mr. Kirkpatrick: 

Pursuant to Section 5c(c) of the Commodity Exchange Act (the “Act”) and Section 40.6(a) of the 

regulations of the Commodity Futures Trading Commission (the “Commission”), DW SEF LLC 

(“DW SEF”) hereby submits amendments to its Rulebook related to the above-captioned Rules. 

Specifically, the Rulebook has been amended as detailed below. 

First, the Rulebook has been amended to clarify that the annual report prepared by the SEF’s 

Regulatory Oversight Committee pursuant to Rule 205(a)(v) is different from the Annual 

Compliance Report that is required to be submitted to the Commission under Rule 212(a)(xiii). 

Additionally, the amended Rule 205 now allows the annual report prepared by the SEF’s 

Regulatory Oversight Committee to be made orally, provided that the report is memorialized in 

Board minutes. The amendment will become effective on February 16, 2022, no fewer than ten 

business days from the date hereof. 

Second, the Rulebook has been amended to reflect the delisting of the Great Britain Pound 

Sterling-denominated Forward Rate Agreement on DW SEF’s electronic trading system. DW SEF 

will delist the Great Britain Pound Sterling-denominated Forward Rate Agreement no earlier than 

February 16, 2022. The Rulebook has also been updated so that the product specifications set 

forth in Rule 901 align with DW SEF’s technical specifications. The amendment will become 

effective on February 16, 2022, no fewer than ten business days from the date hereof. 

In connection with this submission, DW SEF hereby notifies the Commission that: 

1. DW SEF certifies that it has posted a notice of this pending certification with the 

Commission and a copy of this submission on DW SEF’s website, including redlines 

of Rule 205 and Rule 901, which are attached hereto as Attachment A and Attachment 

B respectively, a copy of Rule 205, which is attached hereto as Attachment C, and a 

copy of Rule 901, which is attached hereto as Attachment D; 

2. DW SEF certifies that the Rules comply with the Act and the Commission’s regulations 

thereunder; and 
Mr. Christopher J. Kirkpatrick 

Commodity Futures Trading Commission 

February 2, 2022 

2 

3. No substantive opposing views with respect to the Rules were expressed to DW SEF 

by its governing board or committee members, members of DW SEF or market 

participants. 

Should you have questions regarding this submission, please contact the undersigned at (646) 

767-4923 or by email at Devi.Shanmugham@tradeweb.com. 

Very truly yours, 

Devi Shanmugham 

Dealerweb SEF CCO 

 
Mr. Christopher J. Kirkpatrick 

Commodity Futures Trading Commission 

February 2, 2022 

3 

Attachment A 

Redline Version of Rule 205 
Mr. Christopher J. Kirkpatrick 

Commodity Futures Trading Commission 

February 2, 2022 

4 

Attachment B 

Redline Version of Rule 901 

 
Mr. Christopher J. Kirkpatrick 

Commodity Futures Trading Commission 

February 2, 2022 

5 

Attachment C 

Amended Rule 205 
Mr. Christopher J. Kirkpatrick 

Commodity Futures Trading Commission 

February 2, 2022 

6 

Attachment D 

Amended Rule 901