ICAP-2016-R-3

April 11, 2016

Submitted via CFTC Portal

Division of Market Oversight

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: ICAP SEF (US) LLC –Rule Amendments - Amended Rulebook

Ladies and Gentlemen:

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”), ICAP SEF (US) LLC 

(“ICAP SEF”) hereby notifies the Commission that it has amended its Rulebook, specifically Rules 312 

and 806. The Rulebook has been amended to reflect Commission No-Action Letter (“NAL”) 16-25. 

A concise explanation and analysis of the amendments to the Rulebook and their compliance with 

applicable provisions of the Act and the Commission’s regulations thereunder is attached hereto as 

Exhibit A. A clean copy of the amended Rulebook exclusive of confidential Chapter 9 is attached hereto 

as Exhibit B and a copy of the Rulebook exclusive of confidential Chapter 9 marked to show changes 

against the version submitted to the Commission in ICAP-2016-R-2 is attached hereto as Exhibit C. 

The amendments will become effective on April 25, 2016. ICAP SEF certifies that the amendments 

comply with the requirements of the Commodity Exchange Act and the rules and regulations promulgated 

thereunder. ICAP SEF has reviewed the swap execution facility core principles (“Core Principles”) as set 

forth in the Commodity Exchange Act and has determined that the amendments impact the Core 

Principles identified in Exhibit A.

ICAP SEF is not aware of any substantive opposing views expressed with respect to this filing and 

certifies that, concurrent with this filing, a copy of this submission was posted on the ICAP SEF website 

and may be accessed at: http://www.icap.com/what-we-do/global-broking/sef.aspx. 

Please contact the undersigned at (212) 341-9193 with any questions regarding this matter.

Very truly yours,

Gregory Compa

Chief Compliance Officer

ICAP SEF (US) LLC

1100 Plaza Five

Jersey City, NJ 07311
2

Exhibit A

Explanation and Analysis

1. On March 14, 2016 the Commission published NAL 16-25, which extended the relief previously 

provided in NAL 15-25 to the earlier of March 31, 2017 or the publication of a CFTC regulation 

establishing a permanent confirmation solution for uncleared transactions. References in Rule 

312(c)(4) and (5) to NAL 15-25 have been changed to NAL 16-25.

The amendments are consistent with Core Principle 2 and NAL 16-25.

2. Rule 806 sets forth the product description for Non Deliverable Forwards (“NDFs”). Rule 806 has 

been amended to permit two additional fixing methodologies to be applied to the existing NDF 

contracts: Today’s Fixing (TOD) and Tomorrow’s Fixing (TOM). Both methodologies have been 

added to permit an existing NDF position to be rolled forward one month. The TOD methodology 

permits this based on the fixing rate determined on the trade date. The TOM methodology 

permits the counterparties to roll the position forward based on the differential between the fixing 

rate of the original NDF establishing the currency position and the current market rate for a new 

NDF rolling the position forward. The underlying NDF contracts remain unchanged from those 

previously certified, including the source of the fixing spot rate and trade settlement conventions. 

The amendments are consistent with Core Principles 2 and 3.