UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

Treatment of Funds Held in Connection with 

Clearing by LCH.Clearnet Limited 

ORDER 

LCH.Clearnet Limited ("LCH"), a registered derivatives clearing organization 

("DCO"), has submitted to the Commodity Futures Trading Commission ("Commission") 

a request for an order permitting LCH and its clearing members that are registered futures 

commission merchants ("FCM Clearing Members") to: (i) hold in a cleared swaps account 

subject to Section 4d(f) of the Commodity Exchange Act ("Act"), 7 U.S.C. § 6d(f), 

customer money, securities, and property (collectively, "customer property") used to 

margin, secure, or guarantee both futures and foreign futures (collectively, "futures") and 

cleared swaps; and (ii) provide for portfolio margining of such futures and cleared swaps. 

LCH's request was posted on the Commission's website for public comment. Two 

comment letters were received, and both supported the Commission's issuance of the 

requested relief. 

The Commission has reviewed the request and the record in this matter 

("Submission"), and finds that LCH has demonstrated that it can continue to comply with 

the requirements under the Act and the Commission's regulations thereunder. Therefore, 

IT IS ORDERED, pursuant to Section 4d(f) of the Act, that, subject to the terms 

and conditions below, LCH and its FCM Clearing Members that are acting pursuant to this 

order may hold customer property used to margin, guarantee, or secure trades or positions 
in futures with other customer property used to margin, guarantee, or secure trades or 

positions in cleared swaps in a cleared swaps account or accounts maintained in 

accordance with Section 4d(f) of the Act (including any orders issued pursuant to Section 

4d(f) of the Act) and the regulations thereunder, and provide for portfolio margining of 

such futures and cleared swaps, subject to the requirements of Commission Regulation 

39.13(g)(4). All such customer property shall be accounted for and treated and dealt with 

as belonging to the cleared swaps customers of the participating FCM Clearing Member 

consistent with Section 4d(f) of the Act and the regulations thereunder. 

IT IS FURTHER ORDERED, that: 

(I) This order only permits futures that are currently, or will in the future be, 

cleared through LCH, to be commingled and portfolio margined with cleared swaps that 

are currently, or will in the future be, cleared through LCH, in accounts subject to Section 

4d( f) of the Act. 

(2) LCH and each FCM Clearing Member acting pursuant to this order shall 

hold all customer property deposited with LCH and such FCM Clearing Member, 

respectively, to margin, guarantee, or secure futures, in accordance with the requirements 

of Section 4d(f) of the Act and the Commission's regulations thereunder. 

(3) LCH shall at all times fulfill all representations made in the Submission, 

including all attachments and supporting materials thereto. 

(4) LCH shall promptly inform the Commission of any material change in 

applicable foreign laws or regulations affecting the conclusions contained in the 

Submission. 

This Order is issued pursuant to Section 4d(f) of the Act based upon the 

representations made and supporting materials provided to the Commission by LCH in its 

2 
Submission. Any material changes or omissions in the facts and circumstances pursuant to 

which this order is granted may require the Commission to reconsider its finding that the 

relief set forth herein is appropriate. Further, in its discretion, the Commission may 

condition, modify, suspend, terminate, or otherwise restrict the exemptive relief granted in 

this order, as appropriate, on its own motion. 

Issued in Washington, D.C., this 13th day of January, 2017. 

By the Commission 

<1244-J-.9~ Christopher J. Kirkpatrick 

Secretary of the Commission 

3