July 28, 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: tpSEF Inc. – Regulation 40.2 of Certification of Swiss Franc Non-Deliverable 

Forward Foreign Exchange Contracts (tpSEF Submission #22-17P)

Dear Mr. Kirkpatrick: 

tpSEF Inc. (“tpSEF”) hereby notifies the Commodity Futures Trading Commission (the 

“Commission”) of its intent to list Swiss Franc Non-Deliverable Forward Foreign Exchange 

Contracts (the “Contracts”) on tpSEF’s swap execution facility. tpSEF intends to list the Contracts 

on August 1, 2022. 

Pursuant to Commission Regulation 40.2, this submission includes: 

i. The intended listing date – August 1, 2022;

ii. A certification by tpSEF that: (a) the Contracts comply with the Commodity

Exchange Act, as amended, and the Commission regulations thereunder; and

(b) concurrent with this submission, tpSEF posted on its website: (i) a notice of

pending certification of the Contracts, and (ii) a copy of this submission, attached

as Exhibit A;

iii. The terms and conditions of the Contracts, attached as Exhibit B; and

iv. An explanation and analysis of the Contracts compliance with applicable core

principles and Commission regulations, attached as Exhibit C.

tpSEF is listing the Contracts by virtue of updating the terms and conditions of Non-Deliverable 

Forward Foreign Exchange Contracts originally submitted to the Commission for self-certification 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 2 

pursuant to Commission Regulation 40.2 on September 29, 2013 and last updated December

26, 2019. A copy of the terms and conditions marked to show changes from the version 

submitted on December 26, 2019 is attached as Exhibit D. 

Questions regarding this submission should be directed to Brian Donnelly, Chief Compliance 

Officer, at (201) 984-6956 or by email at bddonnelly@tullettprebon.com. 

Very truly yours, 

tpSEF Inc. 

By: __________________________ 

Name: Brian D. Donnelly 

Title: Chief Compliance Officer 

Date: July 28, 2022 

Enclosures 

cc: CFTC Division of Market Oversight (dmosubmissions@cftc.gov) 

Nancy Markowitz, CFTC (nmarkowitz@cftc.gov) 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 3 

EXHIBIT A 

CERTIFICATIONS PURSUANT TO SECTION 5c OF THE COMMODITY EXCHANGE 

ACT, 7 U.S.C. §7A-2 AND COMMODITY FUTURES TRADING COMMISSION 

REGULATION 40.2, 17 C.F.R. §40.2 

tpSEF Inc. (“tpSEF”) hereby certifies that: (i) Swiss Franc Non-Deliverable Forward Foreign 

Exchange Contracts (the “Contracts”) comply with the Commodity Exchange Act, 7 U.S.C. §1 et 

seq. and Commodity Futures Trading Commission (“Commission”) regulations thereunder; and 

(ii) concurrent with this submission, tpSEF posted on its website: (a) a notice of pending

certification of the Contract with the Commission and (b) a copy of this submission.

tpSEF Inc. 

By: __________________________ 

Name: Brian D. Donnelly 

Title: Chief Compliance Officer 

Date: July 28, 2022 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 4 

EXHIBIT B 

Non-Deliverable Forward Foreign Exchange Contracts 

Terms and Conditions 

Summary: A non-deliverable forward (“NDF”) is an outright 

forward in which the counterparties settle the difference 

between the contracted NDF price or rate and the 

prevailing spot price or rate on an agreed notional 

amount in an agreed settlement currency. 

Reference Currency 

(i.e., Non-Delivery Currency): 

 AOA Angolan Kwanza

 ARS Argentine Peso

 AUD Australian Dollar

 BDT Bangladeshi Taka

 BRL Brazilian Real

 CAD Canadian Dollar

 CHF Swiss Franc

 CLP Chilean Peso

 COP Colombian Peso

 CNY Chinese Renminbi

 DKK Danish Krone

 DZD Algerian Dinar

 EGP Egyptian Pound

 EUR Euro

 GBP Great British Pound

 GHS Ghanaian Cedi

 GTQ Guatemalan quetzal

 HKD Hong Kong Dollar

 IDR Indonesian Rupiah

 ILS New Israeli Shekel

 INR Indian Rupee

 JPY Japanese Yen

 KES Kenyan Shilling

 KRW South Korean Won

 KZT Kazakh Tenge

 LKR Sri Lankan Rupee
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 5 

 MAD Moroccan Dirham

 MUR Mauritian Rupee

 MXN Mexican Peso

 MYR Malaysian Ringgit

 MZN Mozambican Metical

 NGN Nigerian Naira

 NOK Norwegian Krone

 NZD New Zealand Dollar

 PEN Peruvian Nuevo Sol

 PHP Philippine Peso

 PKR Pakistani Rupee

 RUB Russian Ruble

 SEK Swedish Krona

 SGD Singapore Dollar

 TND Tunisian Dinar

 TWD Taiwan Dollar

 TZS Tanzanian Shilling

 UAH Ukrainian Hryvnia

 UGX Ugandan Shilling

 UYU Uruguayan peso

 VEB Venezuelan Bolívar

 VND Vietnamese Đồng

 XAF Central African CFA Franc

 XOF West African CFA Franc

 ZAR South African Rand

 ZMW Zambian Kwacha

Settlement Currency:  AUD Australian Dollar

 CAD Canadian Dollar

 EUR Euro

 GBP British Pound

 JPY Japanese Yen

 USD US Dollar

 CHF Swiss Franc

Quoting Convention and Minimum Increment: Notional amount, as agreed by counterparties. 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 6 

Minimum Size: Notional amount, as agreed by counterparties. 

Notional Currency: Currency in which contract size is expressed, as agreed 

by counterparties. 

Trading Conventions: Buy or Sell which refers to the contract size expressed 

in notional currency. 

Forward Rates: Currency exchange rate expressed as the amount of 

reference currency per unit of settlement currency. 

Trade Date: The date on which parties enter into the contract. 

Settlement Date: Specified settlement or payment date, as agreed by 

counterparties. 

Fixing Date: The date at which the difference between the prevailing 

market exchange rate and the agreed upon exchange 

rate is calculated. 

Settlement Procedure: Bilateral settlement performed in settlement currency. 

Disruption Events: Unless otherwise specified by the parties, as set forth in 

the EMTA Template Terms for Non-Deliverable FX 

Forward Transactions applicable to the Reference 

Currency and Settlement Currency: 

http://www.emta.org/ndftt.aspx 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 7 

EXHIBIT C 

EXPLANATION AND ANALYSIS OF THE CONTRACTS’ COMPLIANCE WITH 

APPLICABLE CORE PRINCIPLES AND COMMISSION REGULATIONS 

As required by Commodity Futures Trading Commission (“Commission”) Regulation 40.2(a), the 

following analysis, in narrative form, demonstrates that Non-Deliverable Forward Foreign Exchange 

Contracts (the “Contracts”) are consistent with the requirements of the Commodity Exchange Act, as 

amended (the “Act”), and the Commission regulations and guidance thereunder (in particular, Appendix B 

to Part 37 and Appendix C to Part 38). 

Appendix B to Part 37 

CORE PRINCIPLE 3 OF SECTION 5H OF THE ACT—SWAPS NOT READILY SUSCEPTIBLE TO 

MANIPULATION; CORE PRINCIPLE 4 OF SECTION 5H OF THE ACT—MONITORING OF TRADING AND 

TRADE PROCESSING 

The swap execution facility shall permit trading only in swaps that are not readily susceptible to 

manipulation. 

(a) Guidance.

(1) In general, a swap contract is an agreement to exchange a series of cash flows over a period of

time based on some reference price, which could be a single price, such as an absolute level or a

differential, or a price index calculated based on multiple observations. Moreover, such a reference

price may be reported by the swap execution facility itself or by an independent third party. When

listing a swap for trading, a swap execution facility shall ensure a swap’s compliance with Core

Principle 3, paying special attention to the reference price used to determine the cash flow

exchanges. Specifically, Core Principle 3 requires that the reference price used by a swap not be

readily susceptible to manipulation. As a result, when identifying a reference price, a swap

execution facility should either: Calculate its own reference price using suitable and wellestablished acceptable methods or carefully select a reliable third-party index.

(2) The importance of the reference price’s suitability for a given swap is similar to that of the final

settlement price for a cash-settled futures contract. If the final settlement price is manipulated, then

the futures contract does not serve its intended price discovery and risk management functions.

Similarly, inappropriate reference prices cause the cash flows between the buyer and seller to differ

from the proper amounts, thus benefitting one party and disadvantaging the other. Thus, careful

consideration should be given to the potential for manipulation or distortion of the reference price.

The Contracts are typical of non-deliverable forwards (“NDFs”), in that the counterparties arrange 

settlement by calculating the difference between the contracted NDF rate, which is agreed on between the 

counterparties at the start of the contract, and the prevailing spot foreign exchange (“FX”) rate, on the fixing 

date. This difference is then multiplied by the notional amount, which is also determined at the start of the 

contract. As such, the reference price is the prevailing spot FX rate on the date/time in which the parties 

agree that the comparison will be made (i.e., fixing date). The source for the spot FX rate on the fixing date 

will be bilaterally agreed and, in a majority of cases, determined by the Central Banks. This information is 

easily accessible to the public. 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 8 

The spot FX rate (i.e., the reference price) is not easily susceptible to manipulation since it is generated 

through a transparent, rules-based process. The reliability of fixing FX rate data is evident in its general

acceptance in the market place as a reliable, unbiased source for FX rate data calculated by Central 

Banks, the Emerging Market Trades Association (“EMTA”) and a number of reputable calculation 

agencies. 

(3) For swaps that are settled by physical delivery or by cash settlement refer to the guidance in

Appendix C to Part 38 of this chapter—Demonstration of Compliance that a Contract is not

Readily Susceptible to Manipulation, section b(2) and section c(4), respectively.

Please see below. 

Appendix C to Part 38 - Demonstration of Compliance That a Contract Is Not Readily Susceptible 

to Manipulation 

(c) Futures Contracts Settled by Cash Settlement. (1) Cash settlement is a method of settling certain

futures or option contracts whereby, at contract expiration, the contract is settled by cash payment

in lieu of physical delivery of the commodity or instrument underlying the contract. An acceptable

specification of the cash settlement price for commodity futures and option contracts would include

rules that fully describe the essential economic characteristics of the underlying commodity (e.g.,

grade, quality, weight, class, growth, issuer, maturity, source, rating, description of the underlying

index and index's calculation methodology, etc.), as well as how the final settlement price is

calculated. In addition, the rules should clearly specify the trading months and hours of trading, the

last trading day, contract size, minimum price change (tick size) and any limitations on price

movements (e.g., price limits or trading halts).

Essential Economic Characteristics of the Contract Terms 

The terms and conditions of the Contracts match the terms of non-deliverable forward FX contracts that 

are commonly offered in the market and are listed in Exhibit B. 

Calculation of Cash Settlement Price 

As noted above and as is typical with non-deliverable forwards, the cash settlement price will be the 

difference between the contracted NDF rate and the prevailing spot FX rate multiplied by an agreed upon 

notional amount. Thus, the settlement will be based on the following: 

 Reference Currency – As determined by the counterparties at the trade date (i.e., start of the

Contracts); available currencies are listed in the Contracts’ terms and conditions (Exhibit B).

 Settlement Currency – As determined by counterparties at the trade date; available currencies are

listed in Contracts’ terms and conditions (Exhibit B).

 Notional Amount – Amount agreed by counterparties at trade date.

 Contracted NDF Rate – Rate agreed by counterparties, expressed as reference currency per unit

of settlement currency.
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 9 

 Spot FX Rate – Exchange rate expressed as reference currency per unit of settlement currency.

The spot FX rate is determined on the fixing date.

 Fixing Date – Date, agreed by counterparties, on which the difference between the spot FX rate

and the contracted NDF rate is calculated.

 Settlement Date – Date, agreed by counterparties, on which settlement payments will be made.

On the fixing date, the parties will agree on the spot FX rate, which will be expressed as reference currency 

per unit of settlement currency. They will calculate the difference between the contracted NDF price/rate 

and the spot price/rate and multiply that difference by the notional amount to arrive at the cash settlement 

price. The cash settlement will be due on the settlement date. This method of calculating settlement for the 

Contracts is a common, widely-used and widely accepted method of calculating the cash settlement for 

non-deliverable forward contracts. 

(2) Cash settled contracts may be susceptible to manipulation or price distortion. In evaluating the

susceptibility of a cash-settled contract to manipulation, a designated contract market should

consider the size and liquidity of the cash market that underlies the listed contract in a manner that

follows the determination of deliverable supply as noted above in (b)(1). In particular, situations

susceptible to manipulation include those in which the volume of cash market transactions and/or

the number of participants contacted in determining the cash-settlement price are very low. Cashsettled contracts may create an incentive to manipulate or artificially influence the data from which

the cash-settlement price is derived or to exert undue influence on the cash-settlement price's

computation in order to profit on a futures position in that commodity. The utility of a cash-settled

contract for risk management and price discovery would be significantly impaired if the cash

settlement price is not a reliable or robust indicator of the value of the underlying commodity or

instrument. Accordingly, careful consideration should be given to the potential for manipulation or

distortion of the cash settlement price, as well as the reliability of that price as an indicator of cash

market values. Appropriate consideration also should be given to the commercial acceptability,

public availability, and timeliness of the price series that is used to calculate the cash settlement

price. Documentation demonstrating that the settlement price index is a reliable indicator of

market values and conditions and is commonly used as a reference index by industry/market agents

should be provided. Such documentation may take on various forms, including carefully

documented interview results with knowledgeable agents.

The Contracts are not readily susceptible to manipulation for a number of reasons. First, the FX market is 

an extremely liquid market with massive volume, making manipulation very difficult to achieve. Second, 

as noted above, the method for calculating the cash settlement price – calculating the difference between 

the spot FX rate and the contracted NDF rate – is widely used and generally accepted by market 

participants. Third, as discussed above, the reference used for the spot FX rate is very reliable and widely 

available, and used by numerous market participants, although some of the currencies and associated 

benchmarks are, of course, less widely traded than others. Finally, tpSEF Inc. (“tpSEF”) has a robust 

market surveillance program that is effectively able to surveil this market, detect uncommon activity and 

investigate any such activity for signs of manipulation. tpSEF staff conduct real-time market surveillance 

and the National Futures Association (“NFA”) provides regulatory services on a T+1 basis. NFA’s 

services include comprehensive trade practice and market surveillance services (the scope of which can 

be found in the Regulatory Services Agreement between NFA and tpSEF submitted to the Commission as 

part of tpSEF’s swap execution facility application) (note that the foregoing also demonstrates 

compliance with Core Principle 4). 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 10 

(3) Where an independent, private-sector third party calculates the cash settlement price series, a

designated contract market should consider the need for a licensing agreement that will ensure the

designated contract market's rights to the use of the price series to settle the listed contract.

(i) Where an independent, private-sector third party calculates the cash settlement price series, the

designated contract market should verify that the third party utilizes business practices that

minimize the opportunity or incentive to manipulate the cash-settlement price series. Such

safeguards may include lock-downs, prohibitions against derivatives trading by employees, or

public dissemination of the names of sources and the price quotes they provide. Because a cashsettled contract may create an incentive to manipulate or artificially influence the underlying

market from which the cash-settlement price is derived or to exert undue influence on the cashsettlement computation in order to profit on a futures position in that commodity, a designated

contract market should, whenever practicable, enter into an information-sharing agreement with

the third-party provider which would enable the designated contract market to better detect and

prevent manipulative behavior.

As described above, the cash settlement price is calculated through a cash settlement method that 

is not easily susceptible to manipulation. 

(ii) Where a designated contract market itself generates the cash settlement price series, the

designated contract market should establish calculation procedures that safeguard against potential

attempts to artificially influence the price. For example, if the cash settlement price is derived by

the designated contract market based on a survey of cash market sources, the designated contract

market should maintain a list of such entities which all should be reputable sources with knowledge

of the cash market. In addition, the sample of sources polled should be representative of the cash

market, and the poll should be conducted at a time when trading in the cash market is active.

Please see above regarding the calculation of the cash settlement price, indicating that the method of 

calculating the cash settlement price is widely accepted in the market 

(iii) The cash-settlement calculation should involve computational procedures that eliminate or

reduce the impact of potentially unrepresentative data.

(iv) The cash settlement price should be an accurate and reliable indicator of prices in the

underlying cash market. The cash settlement price also should be acceptable to commercial users of

the commodity contract. The registered entity should fully document that the settlement price is

accurate, reliable, highly regarded by industry/market agents, and fully reflects the economic and

commercial conditions of the relevant designated contract market.

Please see above regarding the reliability and widespread acceptance of the method used to generate the 

cash settlement price. 

(v) To the extent possible, the cash settlement price should be based on cash price series that are

publicly available and available on a timely basis for purposes of calculating the cash settlement

price at the expiration of a commodity contract. A designated contract market should make the

final cash settlement price and any other supporting information that is appropriate for release to

the public, available to the public when cash settlement is accomplished by the derivatives clearing

organization. If the cash settlement price is based on cash prices that are obtained from non-public

sources (e.g., cash market surveys conducted by the designated contract market or by third parties
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 11 

on behalf of the designated contract market), a designated contract market should make available 

to the public as soon as possible after a contract month's expiration the final cash settlement price 

as well as any other supporting information that is appropriate or feasible to make available to the 

public. 

FX rates are readily available via a number of sources including websites of Central Banks and EMTA. 

(4) Contract terms and conditions requirements for futures contracts settled by cash settlement.

(i) An acceptable specification of the terms and conditions of a cash-settled commodity contract will

also set forth the trading months, last trading day, contract size, minimum price change (tick size)

and daily price limits, if any.

Please see Exhibit B for the Contracts’ terms and conditions. 

(A) Commodity Characteristics: The terms and conditions of a commodity contract should describe

the commodity underlying the contract.

The terms and conditions of the Contracts note that the Contracts are based on the applicable FX rates. 

(B) Contract Size and Trading Unit: An acceptable specification of the trading unit would be a

contract size that is consistent with customary transactions in the cash market. A designated

contract market may opt to set the contract size smaller than that of standard cash market

transactions.

The size of the Contracts, which will be determined by the counterparties, are consistent with customary 

transactions in the market. 

(C) Cash Settlement Procedure: The cash settlement price should be reliable, acceptable, publicly

available, and reported in a timely manner as described in paragraphs (c)(3)(iv) and (c)(3)(v) of this

appendix C.

The cash settlement procedure and an explanation of how, in the context of these Contracts, it is not readily 

susceptible to manipulation, is described above. 

(D) Pricing Basis and Minimum Price Fluctuation (Minimum Tick): The minimum price increment

(tick) should be set a level that is equal to, or less than, the minimum price increment commonly

observed in cash market transactions for the underlying commodity. Specifying a futures’

minimum tick that is greater than the minimum price increment in the cash market can undermine

the risk management utility of the futures contract by preventing hedgers from efficiently

establishing and liquidating futures positions that are used to hedge anticipated cash market

transactions or cash market positions.

As agreed between counterparties. 

(E) Maximum Price Fluctuation Limits: Designated contract markets may adopt price limits to: (1)

Reduce or constrain price movements in a trading day that may not be reflective of true market

conditions but might be caused by traders overreacting to news; (2) Allow additional time for the

collection of margins in times of large price movements; and (3) Provide a “cooling-off” period for

futures market participants to respond to bona fide changes in market supply and demand
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 12 

fundamentals that would lead to large cash and futures price changes. If price-limit provisions are 

adopted, the limits should be set at levels that are not overly restrictive in relation to price 

movements in the cash market for the commodity underlying the futures contract. For broad-based 

stock index futures contracts, rules should be adopted that coordinate with New York Stock 

Exchange (“NYSE”) declared Circuit Breaker Trading Halts (or other market coordinated Circuit 

Breaker mechanism) and would recommence trading in the futures contract only after trading in 

the majority of the stocks underlying the index has recommenced. 

As agreed between counterparties. 

(F) Last Trading Day: Specification of the last trading day for expiring contracts should be

established such that it occurs before publication of the underlying third-party price index or

determination of the final settlement price. If the designated contract market chooses to allow

trading to occur through the determination of the final settlement price, then the designated

contract market should show that futures trading would not distort the final settlement price

calculation.

The last trading day is the fixing date, when the difference between the prevailing market exchange rate 

and the agreed upon exchange rate is calculated. 

(G) Trading Months: Trading months should be established based on the risk management needs of

commercial entities as well as the availability of price and other data needed to calculate the cash

settlement price in the specified months. Specification of the last trading day should take into

consideration whether the volume of transactions underlying the cash settlement price would be

unduly limited by occurrence of holidays or traditional holiday periods in the cash market.

Moreover, a contract should not be listed past the date for which the designated contract market

has access to use a proprietary price index for cash settlement.

The contract will be entered into on the trade date, the settlement price will be determined on the fixing 

date, and the settlement payments will be made on the settlement date. As is common with non-deliverable 

forwards, these dates will be set by the individual counterparties. 

(H) Speculative Limits: Specific rules and policies for speculative position limits are set forth in part

150 and/or part 151, as applicable, of the Commission's regulations.

None required by Parts 150 or 151. 

(I) Reportable Levels: Refer to § 15.03 of the Commission's regulations.

tpSEF will adhere to the applicable reporting levels set forth in § 15.03 of the Commission’s regulations. 

(J) Trading Hours: Should be set by the designated contract market to delineate each trading day.

Each Contract is traded twenty-three hours a day from Sunday to Friday. The Contracts are not traded 

between 5:30 p.m. and 6:30 p.m. Eastern Time. 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 13 

EXHIBIT D

Non-Deliverable Forward Foreign Exchange Contracts 

Terms and Conditions 

(Marked Against December 26, 2019 Version) 

Summary: A non-deliverable forward (“NDF”) is an outright 

forward in which the counterparties settle the difference 

between the contracted NDF price or rate and the 

prevailing spot price or rate on an agreed notional 

amount in an agreed settlement currency. 

Reference Currency 

(i.e., Non-Delivery Currency): 

 AOA Angolan Kwanza

 ARS Argentine Peso

 AUD Australian Dollar

 BDT Bangladeshi Taka

 BRL Brazilian Real

 CAD Canadian Dollar

 CHF Swiss Franc

 CLP Chilean Peso

 COP Colombian Peso

 CNY Chinese Renminbi

 DKK Danish Krone

 DZD Algerian Dinar

 EGP Egyptian pound

 EUR Euro

 GBP Great British Pound

 GHS Ghanaian Cedi

 GTQ Guatemalan Quetzal

 HKD Hong Kong Dollar

 IDR Indonesian Rupiah

 ILS New Israeli Shekel

 INR Indian Rupee

 JPY Japanese Yen

 KES Kenyan Shilling

 KRW South Korean Won

 KZT Kazakh Tenge

 LKR Sri Lankan Rupee
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 14 

 MAD Moroccan Dirham 

 MUR Mauritian Rupee 

 MYR Malaysian Ringgit 

 MXN Mexican Peso 

 MZN Mozambican Metical 

 NGN Nigerian Naira 

 NOK Norwegian Krone 

 NZD New Zealand Dollar 

 PEN Peruvian Nuevo Sol 

 PHP Philippine Peso 

 PKR Pakistani Rupee 

 RUB Russian Ruble 

 SEK Swedish Krone 

 SGD Singapore Dollar 

 TND Tunisian Dinar 

 TWD Taiwan Dollar 

 TZS Tanzanian Shilling 

 UAH Ukrainian Hryvnia 

 UGX Ugandan Shilling 

 UYU Uruguayan Peso 

 VEB Venezuelan Bolívar 

 VND Vietnamese Đồng 

 XAF Central African CFA Franc 

 XOF West African CFA Franc 

 ZAR South African Rand 

 ZMW Zambian Kwacha 

Settlement Currency:  AUD Australian Dollar 

 CAD Canadian Dollar 

 EUR Euro 

 GBP British Pound 

 JPY Japanese Yen 

 USD US Dollar 

 CHF Swiss Franc 

Quoting Convention and Minimum Increment: Notional amount, as agreed by counterparties. 
Mr. Christopher J. Kirkpatrick 

July 28, 2022 

Page 15 

Minimum Size: Notional amount, as agreed by counterparties. 

Notional Currency: Currency in which contract size is expressed, as agreed 

by counterparties. 

Trading Conventions: Buy or Sell which refers to the contract size expressed 

in notional currency. 

Forward Rates: Currency exchange rate expressed as the amount of 

reference currency per unit of settlement currency. 

Trade Date: The date on which parties enter into the contract. 

Settlement Date: Specified settlement or payment date, as agreed by 

counterparties. 

Fixing Date: The date at which the difference between the prevailing 

market exchange rate and the agreed upon exchange 

rate is calculated. 

Settlement Procedure: Bilateral settlement performed in settlement currency. 

Disruption Events: Unless otherwise specified by the parties, as set forth in 

the EMTA Template Terms for Non-Deliverable FX 

Forward Transactions applicable to the Reference 

Currency and Settlement Currency: 

http://www.emta.org/ndftt.aspx