trueEX

September 21, 2016

Via E-Mail: submissions@cftc.gov

Christopher J. Kirkpatrick

Secretary of the Commission

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: trueEX LLC Amendment of Product Terms and Conditions (trueEX LLC 

submission #2016‐08S)

Dear Mr. Kirkpatrick: 

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended, (the “Act”) and 

Commission Regulation 40.6(a), trueEX LLC (“trueEX” or the “Exchange”) hereby 

submits to the U.S. Commodity Futures Trading Commission (the “Commission”) certain 

amendments to the trueEX Rulebook summarized below. 

Summary of Amendments

trueEX Rule Nature of Amendment

• Rule 504 Fraudulent Acts Prohibited

• Rule 508 Market Manipulation Prohibited

Amended language at the request of the CFTC Division of 

Enforcement to ensure these rules regarding fraudulent acts 

and market manipulation are consistent with the Commodity 

Exchange Act and CFTC Regulations.

DCM Core Principle 2 and 12

SEF Core Principle 2

CFTC Regulations 180.1 and 180.2

• Rule 1003(e) – Amended product terms and conditions 

for Overnight Index Swaps for the fixed and floating day 

count conventions eligible for trading.

CFTC Regulation 40.6(a)

Exhibit 1 contains the redlined amendments to Rules 504, 508 and 1003. 

trueEX certifies that this amendments complies with the Act and the Commission’s 

regulations thereunder. trueEX’s analysis of the operation, purpose and effect of the 

proposed rule change and its compliance with the Act, core principles and Commission’s 

regulations thereunder is included in the chart above. There were no substantive opposing 

views expressed by the trueEX governing board or market participants to the rule 

amendments.
trueEX

trueEX certifies that this certification has been concurrently posted on the Exchange’s Web 

Site at http://www.trueex.com/rules-and-notices. These amendments will be effective on 

October 5, 2016. 

If you have questions regarding this notice, please contact me at (312) 320-8934 or by 

email at fran@trueex.com.

Sincerely,

Fran Kenck

Chief Compliance Officer/Chief Regulatory Officer
trueEX

EXHIBIT 1

RULE 504. Fraudulent Acts Prohibited

No Person shall engage in or attempt any fraudulent act or engage in or attempt any

scheme or device to defraud, deceive, trick or mislead in connection with or related

to any activity on or through the Exchange or any activity related to any

Clearing House.

RULE 508. Market Manipulation Prohibited

No Person shall directly or indirectly manipulate, or attempt to manipulate, the price

of any Contract. Corners and attempted corners are prohibited.

RULE 1003. Overnight Index Swap (“OIS”) Contracts

. . . 

(e) Swap Leg Conventions. The terms of Fixed vs. Overnight Index Swaps are 

based on a number of combinations of the criteria below. Approved contracts available 

for trading on the Exchange are itemized in Schedule 1003. 

(i) Fixed Leg (A) Payment Frequency. Monthly, Quarterly, SemiAnnually, Annually or a One Time Bullet payment 

(B) Day Count Convention. 

• Bond Basis (30/360) 

• Money Market Basis (ACT/360)

• ACT/365.FIXED

• ACT/ACT.ISDA 

• 30E/360

• 30E/360.ISDA

• ACT/ACT.ICMA

(C) Holiday Calendar. 

• USD – New York (USNY) 

• EUR – Target (EUTA) 

• JPY – Tokyo (JPTO) 

• GBP – London (GBLO) 

• CAD – Toronto (CATO). 

• CHF – Zurich (CHZU) 
trueEX

(D) Business Day Convention. Modified Following with 

adjustment to period end dates. Business days in this convention must be 

valid business days in respect to Holiday Calendar associated to each 

Currency. If not, it will be the next day that is a business day and if the 

adjusted end dates falls at the end of the month the day rolls to the 

preceding day. 

(E) Fixed Rate. The traded interest rate yield or basis points on 

Trade Date 

(ii) Floating Leg 

(A) Reset Frequency. Daily 

(B) Day Count Convention. 

• Bond Basis (30/360) 

• Money Market Basis (ACT/360)

• ACT/365.FIXED

• ACT/ACT.ISDA 

• 30E/360 94 

• 30E/360.ISDA 

• ACT/ACT.ICMA

(C) Holiday Calendar.

• USD – New York (USNY)

• EUR – Target (EUTA) 

• JPY – Tokyo (JPTO) 

• GBP – London (GBLO)

• CAD – Toronto (CATO) 

• CHF – Zurich (CHZU) 

(D) Business Day Convention. Modified Following with 

adjustment to period end dates. Business days in this convention must be 

valid business days in respect to Holiday Calendar associated with each 

Overnight Interest Rate for the fixing date and the Holiday Center 

calendar associated with the Currency for payment date. If not, it will be 

the next day that is a business day. If the adjusted end dates fall at the end 

of the month, the day rolls to the preceding day. 
trueEX

(E) Overnight Interest Rate

• USD-Federal Funds-H.15-OIS-COMPOUND

• EUR-EONIA-OIS-COMPOUND

• JPY-TONA-OIS-COMPOUND 

• GBP-WMBA-SONIA-COMPOUND 

• CAD-CORRA-OIS-COMPOUND

• CHF-TOIS-OIS-COMPOUND