Exhibit B

Non-Deliverable Forward Contract Specifications

Contract Overview

A non-deliverable forward is a contract in which counterparties settle the
difference between the fixed exchange rate agreed by the parties and the
prevailing spot rate on an agreed notional amount in the settlement currency.

Reference Currency

See currency list attached hereto as Schedule 1.

Reference Currency
Notional Amount

As agreed by the parties.

Settlement Currency

See currency list attached hereto as Schedule 1.

Pre Quotation and
Minimum Price
Increment

The price quotation is determined as a decimal number with five decimal
places. The minimum price change is 0.00005, equivalent to a value of five
units of the quote currency.

Trade Date

The date on which parties enter into the contract

Fixed Exchange Rate

As agreed by the parties, and expressed as the amount of Reference Currency
per unit of Settlement Currency

Fixing Date The date at which the difference between the prevailing spot rate and the fixed
exchange rate is calculated.
Settlement Date As agreed by the parties
Settlement Type Non-Deliverable

Settlement Procedure

Bilateral settlement performed in Settlement Currency

Trading Hours

00:01 -24:00 Sunday-Friday Eastern Time

Clearing Venue

Not applicable

Block Size As set forth in Appendix F to Part 43 of the CFTC Regulations.
Speculative Limits As set in Part 151 of the CFTC Regulations
Reportable Levels As set in CFTC Regulation 15.03

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1000492753

TOP

Tongan Pa'Anga

TRY Turkish New Lira

TTD Trinidad and Tobago Dollar
TWD New Taiwan Dolloar
TZS Tanzanian Shilling

UAH Ukrainian Hryvnia

UGX Ugandan Shilling

USD United States Dollar
UYU Uruguayan Peso

UZS Uzbekistani Som

VEF Venezuelan Bolivar Fuerte
VND Vietnamese Dong

VUV Vanuatu Vatu

WST Samoan Tala

XAF CPA Franc Central Africa
XCD East Caribbean Dollar
XOF CFA Franc West Africa
XPF French Pacific Franc
YER Yemeni Rial

ZAR South African Rand
ZMK Zambian Kwacha

ZMW Zambian Kwacha

ZWR

Zimbabwean Dollar



Schedule 1 to Exhibit B

Code Name

AFN Afghan Afghani

ALL Albanian Lek

AMD Armenian Dram
AOA Angolan Kwanza
ARS Argentine Peso

AUD Australian Dollar
AWG Aruban Florin

AZN Azerbaijani Manat
BAM Bosnia and Herzegovina Convertible Mark
BBD Barbadian Dollar
BDT Bangladeshi Taka
BGN Bulgarian Lev

BHD Bahraini Dinar

BIF Burundian France
BMD Bermudian Dollar
BOB Bolivian Boliviano
BRL Brazilian Real

BSD Bahamian Dollar
BWP Botswana Pula

BYR Belarusian Ruble
BZD Belize Dollar

CAD Canadian Dollar

CDF Franc Congolais

CHF Swiss Franc

CLP. Chilean Peso

CNH Deliverable Chinese Yuan settled in Hong Kong
CNY Chinese Yuan Renminbi
COP Colombian Peso

CRC Costa Rican Colon
CVE Cape Verdean Escudo
CZK Czech Koruna

DJF Djiboutian France
DKK Danish Krone

DOP Dominican Peso
DZD Algerian Dinar

EEK Estonian Kroon

EGP Egyptian Pound

ERN Eritrean Nakfa

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Foreign Currency Option Specifications

Contract Overview

A foreign currency option is a transaction in which the buyer has the right,
but not the obligation, to purchase a fixed amount of foreign exchange at a
fixed exchange rate agreed by the parties for a specified time period.

Reference Currency

See currency list attached hereto as Schedule 1.

Reference Currency
Notional Amount

As agreed by the parties

Settlement Currency

See currency list attached hereto as Schedule 1.

Price Quotation and
Minimum Price

The price quotation is determined as a decimal number with five decimal
places. The minimum price change is 0.00005, equivalent to a value of five

Increment units of the quote currency.

Option Style American or European

Strike Price As agreed by the parties

Expiration Date As agreed by the parties

Expiration Time The time at which the Spot Rate is determined.
Settlement Date As agreed by the parties.

Settlement Procedure Bilateral settlement performed in Settlement Currenc
Settlement Type Non-Deliverable

Premium As agreed by the parties

Premium Payment
Date

As agreed by the parties

Trading Hours

00:01 -24:00 Sunday-Friday Eastern Time

Clearing Venue

Not applicable

Block Size

As set forth in Appendix F to Part 43 of the CFTC Regulations.

Speculative Limits

As set in Part 151 of the CFTC Regulations

Reportable Levels

As set in CFTC Regulation 15.03

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MKD

Macedonian Denar

MNT Mongolian Tugrik
MRO Mauritania Ouguiya
MUR Mauritian Rupee
MWK Malawian Kwacha
MXN Mexican Peso

MYR Malaysian Ringgit
MZN Mozambican Metical
NAD Namibian Dollar
NGN Nigerian Naira

NIO Nicaraguan CA*rdoba
NOK Norwegian Krone
NPR Nepalese Rupee

NZD New Zealand Dollar
OMR Omani Rial

PEN Peruvian New Sol
PGK Papua New Guinean Kina
PHP Philippine Peso

PKR Pakistani Rupee

PLN Polish New Zloty
PYG Paraguayan Guarani
QAR Qatari Rial

RON Romanian New Leu
RSD Serbian Dinar

RUB Russian Federation Ruble
RWF Rwandan Franc

SAR Saudi Arabian Riyal
SBD Solomon Islands Dollar
SCR Seychelles Rupee
SDG Sudanese Pound

SEK Swedish Krona

SGD Singapore Dollar

SLL Sierra Leonean Leone
SRD Surinamese Dollar
SSP South Sudanese Pound
STD Sao Tome Dobra

SYP Syrian Pound

SZL Swazi Lilangeni

THB Thai Baht

TIS Tajikistani Somoni
TND Tunisian Dinar



360 Trading Networks, Inc. - 521 Fifth Avenue, 38" Floor New York, NY 10175 360 Trading Networks, Inc.
521 Fifth Avenue, 38" Floor
New York, NY 10175

Phone: +1 212 776 2900

Fax: +1 212 776 2902
E-Mail: info@360t.com

www.360t.com

September 30, 2013

BY ELECTRONIC MAIL: submissions@cftc.gov

Melissa Jurgens

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Commission Regulation 40.2(a)— Certification of | Non-Deliverable Foreign
Exchange Forwards and Foreign Currency Options

Dear Ms. Jurgens:

Pursuant to Commission Regulation 40.2(a), 360 Trading Networks Inc. (“360T”) hereby
notifies the Commodity Futures Trading Commission (the “Commission”) that it is certifying the
non-deliverable forwards (“NDFs”) and foreign currency options described herein for trading on
360T’s electronic trading platform (the “Trading Platform”). Specifically, 360T certifies the
NDFs and foreign currency options involving the currencies listed on Schedule 1 to Exhibit B.

360T will list all NDFs and all foreign currency options (each, a “Swap,” and collectively, the
“Swaps”) no earlier than October 2, 2013.

This submission letter contains the following attachments:
e The submission cover sheet.
e Attached as Exhibit A, a concise explanation and analysis of the Swaps.

e Attached as Exhibit B, a copy of the rules for the Swaps, which will be published as
contract specifications on 360T’s website in accordance with 360T Rule 308.

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Core Principle 4 — Monitoring of Trading and Trade Processing

Chapter 5 of the Rules prohibits traders from manipulating, distorting the price of, and disrupting
the cash settlement process of the Swaps. Such Rules are enforced by the Market Regulation
Department.

Core Principle 5 — Ability to Obtain Information

Pursuant to the Rules, 360T will have the ability and authority to obtain sufficient information
for each Swap to allow 360T to fully perform its operational, risk management, governance and
regulatory functions and requirements under Part 37 of Commission Regulations.

Core Principle 6 — Position Limits or Accountability
As set forth in Appendix F to Part 43 of Commission Regulations.
Core Principle 7 — Financial Integrity of Transactions

All Swaps that are required to be cleared pursuant to Section 2(h) of the CEA or that are
voluntarily cleared by the counterparties will be submitted for clearing through a DCO. See Rule
1002.

Core Principle 9 — Timely Publication of Trading Information

In accordance with Part 16 of Commission Regulations, 360T will publish daily market volume
data reports for each Swap (or class of Swap) in terms of notional value. In addition, 360T will
publish for each trading day, by tenor of the Swap, the opening price and the high and low
prices. 360T will publish a settlement price for each such Swap except that, in the case of swaps
listed for clearing by a DCO, the applicable settlement price will be the settlement price
established by the DCO and 360T’s website will contain a hyperlink to the relevant settlement
information. See Rule 407.

360T will submit electronic reports of all primary economic terms data for each Swap to a
registered swap data repository as soon as technologically practicable following execution of
such Swap. See Rule 528. All such reports will meet the standards set out in Commission
Regulation 45.3, including the requirement to produce a unique swap identifier for each
transaction. 360T will also issue confirmations of transactions pursuant to Rule 525.

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Exhibit C
360T has determined that the Swaps certified herein bear upon the following Core Principles:
Core Principle 2 — Compliance with Rules

Trading in the Swaps will be subject to the 360T Rulebook (the “Rules”), which prohibits
abusive trading practices, including: acts detrimental to 360T or that are inconsistent with just
and equitable principles of trade (Rule 503), fraudulent acts (Rule 504), fictitious or non-
competitive transactions (Rule 505), market manipulation (Rule 507), disruptive trading
practices (Rule 508), misstatements (Rule 509), misuse of the trading system (Rule 510), wash
sales (Rule 516) and pre-negotiated or non-competitive trades, including money passes (Rule
517). Trading in these Swaps will also be subject to Rules relating to protection of customers.
See Rules 512-513, 518 and 519.

As with all Swaps listed for trading on the Trading System, trading activity in the Swaps will be
subject to monitoring and surveillance by 360T’s Market Regulation Department. 360T has the
authority to exercise its investigatory and enforcement power where potential Rule violations are
identified. See Chapter 7 of the Rules.

Core Principle 3 — Swaps Not Readily Susceptible to Manipulation

NDFs and foreign currency options are cash-settled transactions between two counterparties and
are typically used to either hedge or speculate against currencies where exchange controls in a
particular country make it difficult to trade in the spot market directly. No exchange of the
underlying currency occurs. Instead, the contracts are settled in the settlement currency specified
by the parties, which is typically the U.S. dollar or the Euro.

Swaps in some currencies are fixed against a daily rate published by the relevant central bank of
that country, while other Swaps are fixed based on rates that are an average of interbank prices
displayed on Reuters or other recognized commercial market data vendors. In this regard,
Reuters polls a panel of banks on their estimate of the exchange rate for each currency every day
at a particular local time. The top and bottom quarter of estimates are taken out, and the fixing is
the average of the remaining estimates.

The Swaps are not readily susceptible to manipulation for a number of reasons. First, the foreign
exchange 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
is widely used and generally accepted by market participants. Third, as discussed above, the
reference used for the spot exchange rate is very reliable and widely available, and used by
numerous market participants. And last, 360T 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.

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ETB Ethiopian Birr
EUR Euro

FJD Fijian Dollar

GBP Great British Pound
GEL Georgian Lari
GHS Ghanaian Cedi
GMD Gambian Dalasi
GNF Guinean Franc
GTQ Guatemalan Quetzal
GYD Guyana Dollar
HKD Hong Kong Dollar
HNL Honduran Lempira
HRK Croatian Kuna
HTG Haitian Gourde
HUF Hungarian Forint
IDR Indonesian Rupiah
ILS New Israel Shekel
INR Indian Rupee

IQD Iraqi Dinar

IRR Iranian Rial

ISK Icelandic Krona
JMD Jamaican Dollar
JOD Jordanian Dinar
JPY Japanese Yen

KES Kenyan Shilling
KGS Kyrgyzstani som
KHR Cambodian Riel
KRW South Korean Won
KWD Kuwaiti Dinar
KYD Cayman Islands Dollar
KZT Kazakhstani Tenge
LAK Lao Kip

LBP Lebanese Pound
LKR Sri Lanka Rupee
LRD Liberian Dollar
LSL Lesotho Loti

LTL Lithuanian Litas
LVL Latvian Lats

LYD Libyan Dinar
MAD Moroccan Dirham
MGA Malagasy Ariary



Exhibit A
Below is a concise explanation and analysis of the Swaps:
Non-Deliverable Forwards

360T hereby certifies NDFs involving the currencies listed on Schedule 1 to Exhibit B. Each
NDF is a cash-settled swap where the settlement obligations of the parties is determined by
calculating the difference between the forward rate, which is agreed on between the parties at the
start of the contract, and the prevailing spot exchange rate on the fixing date. This difference is
then multiplied by the notional amount, which is also determined at the start of the contract. The
price source for the spot exchange rate on the fixing date will be bilaterally agreed and, in
majority of cases, determined by various central banks or as public by recognized commercial
market data vendors. This information is easily accessible to the public.

Foreign Currency Options

360T hereby certifies foreign currency options involving the currencies listed on Schedule 1 to
Exhibit B. A foreign currency option is a contract giving the option purchaser (the buyer) the
right, but not the obligation, to buy or sell a fixed amount of foreign exchange at a fixed price per
unit for a specified time period. The foreign exchange options that will be listed for trading by
360T will be cash settled. This means that any payments are made in the settlement currency,
and that payments are not made in the reference currency.

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In the event that you have questions, please contact the undersigned at 44 020 3508 6344 or
martin.oakley@360t.com.

Sincerely,

fs /) f
a
Martin Oakley /

Chief Compliance Officer

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¢ Attached as Exhibit C, a concise explanation and analysis of the Swaps’ compliance with

applicable provisions of the Commodity Exchange Act (the “CEA”), including the Core
Principles, and the Commission’s Regulations thereunder.

360T certifies that each Swap complies with the CEA and Commission Regulations thereunder.

360T additionally certifies that it has concurrently posted a copy of this submission letter and
attachments hereto on 360T’s website at www.360t.com.

* * *

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