e 

Bloomberg SEF LLC 731 Lexington Avenue Tel +1 212 318 2000 

New York, NY 10022 bloombergsef.com

November 1, 2022 

Submitted via Portal

Melissa Jurgens

Office of the Secretariat 

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581 

Re: Bloomberg SEF LLC – Certification 2022-R-06 (Notice to Participants) 

Dear Sir or Madam: 

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

regulations of the U.S. Commodity Futures Trading Commission (the “CFTC”, or the 

“Commission”), Bloomberg SEF LLC (“BSEF”) hereby notifies the Commission that 

Bloomberg SEF released the Participant Bulletin attached hereto on September 22, 2022 (the 

"Notice"). 

The Notice informed Participants about actions that Participants may be required to take 

resulting from the CFTC revisions to Parts 43 and 45 SDR Reporting Rules effective December

5, 2022. 

BSEF hereby certifies that: (i) the Participant Bulletin complies with the Act and the 

Commission’s regulations thereunder, and (ii) a notice and copy of this submission is being

concurrently posted on BSEF’s website. There were no substantive opposing views to the 

Notice. 

600365904 
Please contact the undersigned at (212) 617-7331 with any questions regarding this matter. 

Chief Compliance Officer 

Bloomberg SEF LLC 

731 Lexington Avenue 

New York, NY 10022 

cc: Marilee Dalman, Division of Market Oversight, U.S. Commodity Futures Trading 

Commission 
BLOOMBERG SEF LLC 

Notice to Participants No. 2022-2

PARTICIPANT BULLETIN SEPTEMBER 22, 2022

CFTC SDR Reporting Rules Effective December 5, 2022 (New SDR Reporting Rules) and 

Participants’ Obligation to Review and Update Their ENFB Fields.

BSEF and other market participants are required to comply with the New SDR Reporting Rules by 

December 5, 2022. As a result of these new rules, BSEF is implementing several new enhancements to 

its ENFB system, which, for many Participants, may require them to confirm existing information 

maintained in ENFB and/or provide additional information in ENFB. This communication outlines these 

new requirements and the actions that Participants may be required to take. 

Capitalized terms used, but not defined herein, have the meanings assigned to them in the BSEF 

Rulebook, which is available at https://www.bloomberg.com/professional/product/sef-compliance/. 

All changes described in this Bulletin will take effect upon Rule certifications with the CFTC. 

A. TRADING STATUS AND ALLOCATION INDICATOR

BSEF will be required to assign a new type of “allocation indicator” to each Trade executed by BSEF.1 To 

comply with this requirement, BSEF is establishing a workflow that is designed to determine the 

appropriate allocation indicator for each Trade executed on the SEF operated by BSEF. To achieve this, 

BSEF will use the information a Participant has provided in the “Trading Status” field in ENFB. The 

assignment of the new allocation indicator will take effect on December 5, 2022.

All Participants are required to select one of the options indicated below as their Trading Status. Please 

contact a BSEF representative if your firm will be using BSEF in more than one trading capacity. It is 

important that a Participant establishes a separate ENFB page for each Trading Status if needed based 

on the Participant’s facts and circumstances. This will help ensure that the Participant executes each 

Trade using the appropriate Trading Account and such Trade has the accurate allocation indicator. 

Participants will be able to make new elections starting on August 15, 2022. 

Agent - Asset Manager

Agent - Direct Market Access Customer

Agent - FCM

Agent - Inter-Dealer Broker (not CFTC-registered)

Agent - Introducing Broker

Agent – Corporate Treasury

Principal - Swap Dealer/MSP

Principal - Non Swap Dealer/MSP

Principal - Direct Market Access Customer

Principal - FCM

Sponsoring Broker

If a Participant has already elected its Trading Status, and provided it does not amend such Trading 

Status, then on December 5, 2022, its Trading Status will be re-assigned as shown in Table 1 below:

1 See Appendix 1 to Part 45, Data Element 91 (Allocation indicator). The definition of this Data Element requires an 

“[i]ndicator of whether the swap transaction is intended to be allocated, will not be allocated, or is a post-allocation 

transaction.” The CFTC Technical Specification dated September 30, 2021 prescribes the use of one of the following 

appropriate indicators: POST = An indication that the transaction is the result of an allocation; PREA = An indication 

that the transaction is to be allocated; or UNAL = An indication that the transaction is not a post-allocated transaction 

and/or is not to be allocated. 
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Table 1.

If currently selected: Then the new value will be:

Unspecified

Agent - Asset Manager if Participant’s Reporting Status is Financial 

Entity

Principal - Swap Dealer/MSP if Participant’s Reporting Status is 

Swap Dealer or MSP

Principal - Non Swap Dealer/MSP if Participant’s Reporting Status 

is Other

Agent Agent - Asset Manager

Asset Manager Agent - Asset Manager

Direct Market Access 

Customer Agent - Direct Market Access Customer

FCM Agent - FCM 

Inter-Dealer Broker Agent-Inter-Dealer Broker (not CFTC-registered)

Introducing Broker Agent - Introducing Broker

Principal - Non Swap 

Dealer/MSP Principal - Non Swap Dealer/MSP

Principal - Swap Dealer/MSP Principal - Swap Dealer/MSP

Sponsoring Broker Sponsoring Broker

Please note that “unspecified” Trading Status selection exists for the initial set-up purpose only and no 

Participant will be approved for trading on BSEF if it selected “unspecified” as its Trading Status.

In addition to verifying or updating their Trading Status on ENFB, Participants that plan to “allocate” 

transactions to a single Account must provide the LEI of that Account. Allocation to a single Account is 

not considered an “allocation” within the meaning of CFTC Rules 45.1 and 45.3(c) and cannot be 

reported with the allocation indicator PREA and the LEI of a Participant acting as an agent. Failure to 

provide the LEI of the Account will result in inaccurate SDR reporting and a potential violation of the 

BSEF Rulebook by a Participant acting as an agent. Participants should refer to CFTC Rules 45.3(c), 

45.4(c) and 45.5 (e) with respect to the reporting obligations for allocated swaps.

Based on the Trading Status that a Participant selects, BSEF will report to an SDR the Allocation Status 

for a Participant’s Trade as follows:

Participants Trading in an Agent Capacity:

Reporting a Trade with a Participant LEI and an allocation indicator of “UNAL” will not be permitted.

If no allocations are provided, the Trade will be reported with the allocation indicator “PREA” and 

the LEI of the Participant.

If multiple allocations are provided, the Trade will be reported with the allocation indicator “PREA” 

and the LEI of the Participant.

If only one allocation is provided, the Trade will be reported with the allocation indicator “UNAL” 

and the LEI of the Account.
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Participants Trading in a Principal Capacity:

Multiple allocations will not be permitted. Reporting of a trade with Participant LEI and allocation indicator 

“PREA” will not be permitted.

All Trades will be reported with the allocation indicator “UNAL” and the LEI of the Participant.

Participants Acting as a Sponsoring Broker:

The allocation indicator will be calculated based on the Trading Status of Participant’s Direct Market 

Access Customers.

Participants Trading Foreign Exchange Asset Class Using a Prime Broker:

Participants trading foreign exchange asset class through a prime broker must provide to BSEF the LEI of 

the prime broker. A Trade executed by BSEF will be reported with an allocation indicator UNAL and LEIs 

of the liquidity provider and the prime broker. 

In light of these changes, Participants are directed to visit ENFB to verify and update their Trading Status 

as soon as possible. BSEF Participants are required under Rules 301(e) and 524 of BSEF’s Rulebook to 

keep their records current and up to date in BSEF’s onboarding and Participant records database. Failure 

to provide up-to-date and accurate Participant information may result in inaccurate reporting of the 

allocation status to an SDR and a disciplinary action by BSEF. 

B. FEDERAL ENTITY INDICATOR

New SDR Reporting Rules will require BSEF to indicate whether each counterparty to a Trade is a 

“federal entity”.2 To comply with this requirement BSEF requests each Participant to indicate its status as 

a federal entity in ENFB (YES/NO). 

BSEF will set the default value of the federal entity indicator to “NO”. A Participant will be able to change 

the value to “YES”. It is an obligation of a Participant to change it to “YES” if the Participant is a federal 

entity.

In light of these changes, Participants are directed to visit ENFB to verify and update their Federal Entity 

Indicator as soon as possible. BSEF Participants are required under Rules 301(e) and 524 of BSEF’s 

Rulebook to keep their records current and up to date in BSEF’s onboarding and Participant records 

database. Failure to provide up-to-date and accurate Participant information may result in inaccurate SDR 

reporting and a disciplinary action by BSEF. 

C. CLEARING EXEMPTION INDICATOR AND NEW CLEARING EXEMPTION CATEGORIES

2 See Appendix 1 to Part 45, Data Elements 23 (Counterparty 1 federal entity indicator) and 24 (Counterparty 2 

federal entity indicator). 
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New SDR Reporting Rules have amended the requirements for reporting clearing exemptions and 

exceptions to an SDR. Please see below in Table 2 the corresponding old and new values. No action is 

required by Participants with respect to these changes.

Table 2

ENFB Display

Old Value New Value

None None

Cooperative Cooperative (COOP)

End User /Affiliate - Agent Entity Affiliate - Agent Entity (OTHR)

End User /Bank Holding Company Bank Holding Company (OTHR)

End User /Captive Finance Company Captive Finance Company (OTHR)

End User /Community Development Financial 

Entity

Community Development Financial Institution

(OTHR)

End User /Credit Union Credit Union (SMBK)

End User /Eligible Treasury Affiliate Eligible Treasury Affiliate (NOAL)

End User /Farm Credit System Institution Farm Credit System Institution (SMBK)

End User /Insured Small Bank FDIC-Insured Small Bank (SMBK)

End User /Not a Financial Entity End User /Not a Financial Entity (ENDU)

End User /Savings and Loan Holding Company Savings and Loan Holding Company (OTHR)

End User /Savings Association Savings Association (SMBK)

Inter-Affiliate Inter-Affiliate (AFFL)

Central Bank/Sovereign (OTHR)

International Financial Institution (OTHR)

Per CFTC Rules 50.75 and 50.76, BSEF added two new categories of Participants eligible for a clearing 

exemption: Central Bank/Sovereign and International Financial Institution. 

Participants can select these new clearing exemptions on the ENFB Clearing tab if they would like to take 

advantage of them starting from December 5, 2022.

DELAYED REPORTING OF TRADES ABOVE THE APPROPRIATE BLOCK SIZE

To streamline compliance with CFTC Rule 43.6(h)(Required Notifications), BSEF will introduce a new rule 

regarding the Block Trade Election Indicator.3 Under the new rule BSEF will report to an SDR any trade 

that is equal to or greater than the minimum size designated for a Block Trade4that is executed outside 

3

See Appendix 1 to Part 45, Data Element 93 (Block trade election indicator). The definition of this Data Element is:

“Indicator whether an election has been made to report the swap transaction as a block transaction by the 

reporting counterparty or as calculated either by the swap data repository acting on behalf of the reporting 

counterparty or by using a third party.” 

4

See the definition of a Block Trade in Chapter 1 of BSEF’s Rulebook: “Block Trade” means a single Swap 

transaction publicly reportable under Part 43 of the CFTC Regulations that: (a) Involves a Swap that is listed on 

BSEF; (b) Occurs away from the SEF Platform or is executed using functionality on the SEF Platform that is not the 
600699187v21

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an Order Book with the Block Trade Election Indicator. By assigning to such Block Trades the Block 

Trade Election indicator, BSEF will request an SDR to apply the appropriate reporting delay5to any 

Participant’s Block Trade that is not executed on an Order Book. 

D. OTHER DATA ELEMENTS REQUIRED TO BE REPORTED BY NEW PART 45 OF CFTC RULES

BSEF continues to evaluate if it is necessary to obtain any additional data elements required to be 

reported to an SDR. Specifically, BSEF is evaluating if it will request certain Participants to provide an 

Initial Margin Collateral Portfolio Code and Variation Margin Portfolio Collateral Code and will inform 

Participants if any additional action is required in connection with these data elements. 

Effective Date: November 16, 2022

Order Book; (c) Has a notional or principal amount at or above the Appropriate Minimum Block Size applicable to 

such Swap; and (d) Is reported as set forth in Rule 532.

5

See CFTC Rule 43.6. Pursuant to CFTC Rule 43.5(d), as of the date of this Bulletin, the time delay is 15 minutes.