CORPORATE

VIA CFTC Portal

9 November 2023

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

RE: Updated LCH SA CDSClear Fee Grid for 2024

Dear Mr. Kirkpatrick,

Pursuant to Commodity Futures Trading Commission (“CFTC”) regulation §40.6(a), LCH SA, a derivatives

clearing organization (“DCO”) registered with the CFTC, is submitting for self‐certification the updated

CDSClear fee grid (“Fee Grid”) to be applicable in 2024 (the “Proposed Rule Change”).

The new Fee Grid applicable to the CDSClear service is expected to be effective as of January 2, 2024

however, in no event, will either be implemented earlier than 10 business days after the Proposed Rule

Change is filed with the CFTC.

The text of the Proposed Rule Change is attached hereto as Appendix A. 1

Part I:  Explanation and Analysis

The purpose of the Proposed Rule Change is for LCH SA CDSClear to amend its Fee Grid for linear and

options products by incorporating changes in the CDSClear business and new clearing services offered.

The Proposed Rule Change reflects the ongoing development and new product scope of the CDSClear

service with the objective to meet clearing members’ and clients’ evolving business needs.

Part II:  Description of Rule Changes

As specified in Appendix A, LCH SA is proposing to amend the CDSClear Fee Grid for 2024 as follows:

Linear Products

1) Self‐Clearing Tariff for Corporates, Financials and Sovereign Index and Single Name CDS

a. General Member Unlimited Tariff

1 All capitalized terms not defined herein shall have the same definition as in the CDS Clearing Rules.
2 

CORPORATE

LCH SA is proposing to clarify that the Annual Fixed Fee of €1,350,000 will be charged at a rate of 1/12th

for each month the Clearing Member group is live. A footnote will be added to the Fee Grid to state that

a Clearing Member is considered live for the whole month regardless of the go‐live date within the

considered month. LCH SA also proposes to amend the “Details” column of the Fee Grid to clarify that

the Annual Fixed Fee applies to all indices and all non‐sovereign single names activity for a Financial

Group of a Clearing Member. LCH SA also proposes to remove reference to the full discount applied to

sovereign single name variable fees, as the discount will no longer apply.

b. General Member – Introductory Tariff

LCH SA is proposing to apply a single annual fixed fee of €400,000 for the General Member’sIntroductory

Tariff. As such, LCH SA is subsequently proposing to remove the €200,000 rebate if a General Member’s

notional amount cleared is below €10bn. LCH SA also proposes to delete the reference to the rebate

under the Introductory Tariff heading, as this would no longer be applicable. In addition, as part of this

revision to the Fee Grid, LCH SA is proposing to clarify that the fixed fee will be charged at a rate of 1/12th

for each month the General Member is live. Finally, LCH SA will add a footnote to state that a General

Member is considered live for the whole month regardless of the go‐live date within the considered

month.

c. Select Members

For Select Members, LCH SA is proposing amendments to certain footnotes under the “Select

Membership” heading. Specifically, LCH SA is proposing to clarify that the Annual Fixed Fee for Select

Members will be charged 1/12th for each month the Select Member is live. This amended footnote will

apply to the Annual Fixed Fee of €450,000 for total annual gross notional cleared over €10bn. LCH SA

also proposes to add a footnote clarifying the rebate available to Select Members. If a Select Member’s

total annual gross notional cleared is under €10bn and the Select Member is live for the whole calendar

year (January 1st – December 31st), LCH SA will provide a €200,000 rebate in the Select Member’s

December bill.  

d. Onboarding Fees

For new Clearing Member onboardings in 2024, LCH SA is proposing to add a €15,000 onboarding fee to

be charged per each Legal Entity under the Introductory Tariff or per Financial Group of a Clearing

Member under the Unlimited Tariff, for the purposes of cost recovery. LCH SA will apply this to all

application files received after January 1st, 2024.

e. Annual Account Structure Fees

LCH SA offers Legally Segregated Operationally Commingled (“LSOC”) accounts to Clearing Members of

CDSClear, in addition to Individual Segregated Accounts and Omnibus Segregated Accounts. LCH SA is

proposing not to charge a yearly fee for LSOC accounts for LSOC accounts under the Proposed Rule.
3 

CORPORATE

2) Client Clearing Tariff for Corporate, Financials and Sovereign Index and Single Names CDS

a. Intraday Trading Fee Plan

LCH SA is proposing to add an intraday trading fee discount which will be applied by only charging the

maximum notional of buys and sells per contract per day per trade account, where trade date is equal

to clearing date. LCH SA also proposes to exclude backloads and option exercises from the discount.

b. CCP Switch Programme

LCH SA is proposing to amend the first footnote to clarify that the CCP Switch Programme is available to

market participants and applicable to live CCP trades beginning on January 2nd, 2024 onwards. LCH SA is

not proposing any other amendments to this section of the Fee Grid.

c. High Turnover Fee Plan

LCH SA offers a High Turnover Fee Plan (“HTFP”) based on notional cleared. LCH SA is proposing to amend

the footnote to clarify that the HTFP applies on the notional cleared in a calendar year but excludes from

the determination of the total cleared notional, the trades not charged under the Intraday Trading Fee

Plan or the CCP Switch Programme. LCH SA is not proposing any other amendments to this section of

the Fee Grid.

Options Products

1) General Members

a. Introductory Tariff

LCH SA is proposing to clarify the Introductory Tariff floor on clearing fees will be charged 1/12th for each

month a General Member Group is live. A footnote will be added to the Fee Grid to state that a General

Member is considered live for the whole month regardless of the go‐live date within the considered

month. LCH SA also proposes to clarify that there will be no EEP usage fees in 2024, as reference to 2023

will no longer be applicable.

b. Unlimited Tariff

LCH SA is proposing to clarify the Unlimited Tariff annual fixed fee will be charged 1/12th for each month

a Member Group is live.  A footnote will be added to the Fee Grid to state that a Member is considered

live for the whole month regardless of the go‐live date or the membership termination date within the

considered month. LCH SA also proposes to clarify that there will be no EEP usage fees in 2024, as

reference to 2023 will no longer be applicable. LCH SA also currently offers a discounted rate of €115,000

for notional cleared strictly above €15bn. LCH SA is proposing to clarify that it will provide a €260,000

rebate to the Clearing Member’s December bill if the General Member Group is live for the whole

calendar year (January 1st – December 31st).

c. New Market Participant Tariff

LCH SA is proposing to clarify that there will be no EEP usage fees in 2024, as reference to 2023 will no

longer be applicable. LCH SA is not proposing any other amendments to this section of the Fee Grid.
4 

CORPORATE

d. Onboarding Fees

LCH SA is proposing to reduce its current onboarding fee from €30,000 to €15,000 per legal entity under

the Introductory Tariff or per Financial Group of a Clearing Member under the Unlimited Tariff. LCH SA

is not proposing any other amendments to this section of the Fee Grid.

2) Select Members

a. Introductory Tariff

LCH SA is proposing to clarify that there will be no EEP usage fees in 2024, as reference to 2023 will no

longer be applicable. LCH SA is not proposing any other amendments to this section of the Fee Grid.

b. Unlimited Tariff

LCH SA is proposing to clarify that there will be no EEP usage fees in 2024, as reference to 2023 will no

longer be applicable. LCH SA is also proposing to clarify the Unlimited Tariff annual fixed fee will be

charged 1/12th for each month a Select Member islive.  A footnote will be added to the Fee Grid to state

that a Select Member is considered live for the whole month regardless of the go‐live date within the

considered month. LCH SA also currently offers a discounted rate of €115,000 for notional cleared strictly

above €15bn. LCH SA is proposing to clarify that it will provide a €285,000 rebate to the Select Member’s

December bill if the Select Member is live for the whole calendar year (January 1st – December 31st).

c. Onboarding Fees

LCH SA is proposing to reduce its current onboarding fee from €30,000 to €15,000 per Legal Entity under

the Introductory Tariff or per Financial Group of a Select Clearing Member under the Unlimited Tariff.

LCH SA is not proposing any other amendments to this section of the Fee Grid.

3) Clients

a. Variable Fees

LCH SA is proposing to apply the full discount of client variable fees to 2024, as 2023 will no longer be

applicable. LCH SA is not proposing any other amendments to this section of the Fee Grid.

Other Fees

1) Archived Report Fees

LCH SA is also proposing to establish a fee structure for the retrieval of archived files. This proposed

change will establish the fee structure currently applicable to LCH SA’s EquityClear and RepoClear

services. Specifically, LCH is proposing to charge a fee of €500 for the first archived file retrieval and €250

for each additional archived file retrieval. For ancillary requests, including ad hoc requests related to

investigations, analysis and data and analytics, LCH SA is proposing to charge a fee based on time spent

on the request. LCH SA is proposing to charge €500 for 1⁄2 day, €1,000 for 1 day and €500 for each

additional 1⁄2 day. LCH SA is also proposing to clarify that the charge for certain large requests (i.e., >50

files) will be provided in a quote as determined by LCH SA. In addition, LCH SA is also proposing to clarify

that it will provide a more tailored estimate for each ancillary request received. To clarify, the proposed
5 

CORPORATE

archived report fee structure is currently implemented for EquityClear and RepoClear, and LCH SA is

proposing to extend to CDSClear as well.

Part III: Core Principle Compliance

LCH SA reviewed the Proposed Rule Change against the requirements of the Commission’s regulations

and DCO Core Principles and has concluded that its compliance with all the requirements and standards

therein, and in particular with the following Core Principle and Commission’s regulations including, but

not limited to CFTC Regulation 39.21, would not be adversely affected by the Proposed Rule Change.

DCO Core Principle L – Public Information. LCH SA has determined that the Proposed Rule Change is

consistent with CFTC Regulation 39.21 to make available publicly each clearing and other fee charged to

Clearing Members.  The proposed changes to the Fee Grid will be publicly available on the LCH website

and LCH SA will ensure that sufficient information is provided to market participants so that they can

identify and evaluate accurately the fees associated with using the relevant clearing services. The LCH

website listing CDSClear fees will be updated with the proposed changes set out in Appendix A once

authorized and effective. As a result, LCH SA believes that the Proposed Rule Change is consistent with

the requirements of Core Principle L and CFTC Regulation Rule 39.21.

Part IV: Public Information

LCH SA has posted a notice of pending certifications with the CFTC and a copy of the submission on LCH’s

website at: https://www.lch.com/resources/rulebooks/proposed‐rule‐changes.

Part V: Opposing Views

There were no opposing views expressed to LCH SA by governing board or committee members,

members of LCH SA or market participants that were not incorporated into the Proposed Rule Change.

Certification

LCH SA hereby certifies to the CFTC, pursuant to the procedures set forth in the Commission regulation

§ 40.6, that the attached submission complies with the Commodity Exchange Act, as amended, and the

regulations promulgated thereunder.

Should you have any questions please contact me.  

Best regards,

Anne Favé  

Interim Chief Compliance Officer

+33 1 70 37 65 97

anne.fave@lseg.com  
APPENDIX A

CORPORATE

Proposed CDSClear Fee Grid effective from January 2nd, 2024*  

Self‐Clearing Tariff for Corporates, Financials and Sovereign Index and Single Name CDS

Membership Annual Fixed Fee Self‐Clearing / Variable Fees   

EUR

Indices

EUR

Single

Names

USD

Indices

USD

Single

Names

General

Member –

Unlimited

Tariff

€ 1,350,000 charged 1/12th

for each month the

Member Group is live****

No Variable Fee Covers all self‐clearing:

‐ Corporate and

Financials Index and

Single Name activity

‐ Sovereign Index

activity

‐ All indices and all non‐

Sovereign Single

Names activity

for a Financial Group of

a Clearing Member  

Fixed Fee: €180,000 No Variable Fees   

General Members –

Unlimited can choose

between the Fixed Fee

Tariff and the Variable

Fees for their Sovereign

Single Name CDS

clearing activity.

In‐year switches

permitted once per year

between the Fixed Fee

Tariff and the Variable

Fees one, and effective

from the start of the

next month following a

15 business days’ notice

period. The Fixed Fee

Tariff covers all self‐

clearing Sovereign

Single Name activity for

a Financial Group of a

Clearing Member

Variable Fees NA €10

Per €

million

gross

notional

cleared

NA $13

Per $

million

gross

notional

cleared

Full discount of Sovereign Single Names

variable fees from 14‐Dec‐2022 to 14‐

Dec‐2023 included
CORPORATE

General

Member –

Introductory

Tariff

€200,000 if the total annual

gross notional cleared is

under €10billion (**)

€3.5

Per

million

gross

notional

cleared

€10

Per

million

gross

notional

cleared

$4.5

Per

million

gross

notional

cleared

$13

Per

million

gross

notional

cleared

Covers all self‐clearing

Corporate, Financial and

Sovereign Index and

Single Names activity

The fixed fee is charged

assuming more than

€10bn notional will be

cleared. Any amount

overdue (for GMs

having cleared less than

€10bn will be returned

to the Member in the

last bill of the year)

€400,000 if the total annual

gross notional cleared is

over €10billion (**) charged

1/12th for each month the

Member is live 

€3.5

Per

million

gross

notional

cleared

€10

Per

million

gross

notional

cleared

$4.5

Per

million

gross

notional

cleared

$13

Per

million

gross

notional

cleared

Full discount of variable fees for Sovereign Single Names from 14‐Dec‐2022 to 14‐Dec‐2023

included

Select

Member

€250,000 if the total annual

gross notional cleared is

under €10billion (** *)

€4

Per

million

gross

notional

cleared

€10

Per

million

gross

notional

cleared

$5

Per

million

gross

notional

cleared

$13

Per

million

gross

notional

cleared

Covers all self‐clearing

Corporate, Financials

and Sovereign Index and

Single Names activity

The fixed fee is charged

assuming more than

€10bn notional will be

cleared. Any amount

overdue (for SMs having

cleared less than €10bn

will be returned to the

Member in the last bill

of the year)

€450,000 if the total annual

gross notional cleared is

strictly over €10billion (***)

(**) Introductory Tariff

 An annual Membership and clearing fixed fee of €400,000 is charged by the Clearing House to cover all

self‐clearing Corporate, Financials and Sovereign Index and Single Names activity.

 If the total annual gross notional cleared is under €10bn, the Clearing House will provide a €200,000 rebate

in the last bill of the year.

 One twelfth of this fee will be charged each month in addition to the variable fee

(***) Select Membership
CORPORATE

 An annual Membership and clearing fixed fee of €450,000 is charged by the Clearing House to cover all

self‐clearing Corporate, Financials and Sovereign Index and Single Names activity, charged 1/12th for each

month the Member is live .

 If the total annual gross notional cleared is under €10bn and the Member is live for the whole calendar

year (January 1st – December 31st), the Clearing House will provide a €200,000 rebate in the last December

bill of the year.

 One twelfth of this fee will be charged each month in addition to the variable fee

(** **) Live Members

 A Member is considered live for the whole month regardless of the go‐live date or the membership

termination date within the considered month.

Client Clearing Tariff for Corporate, Financials and Sovereign Index and Single Names CDS

Client Clearing Self‐Clearing / Variable Fees   

EUR Indices EUR Single

Names

USD

Indices

USD

Single

Names

Variable Fees €4

Per million gross notional

cleared

€12

Per million

gross notional

cleared

$5

Per

million

gross

notional

cleared

$17

Per

million

gross

notional

cleared

Covers all self‐

clearing

Corporate,

Financials and

Sovereign Index

and Single

Names activity.

Intraday Trading Fee Plan Only the maximum

notional of buys and sells

per contract per day per

trading account will be

charged and where.

trade date is equal to

clearing date.

Annual Account Fees

A yearly fee is charged for each ISA or OSA account as indicated in the table below.

ISA OSA Net OSA Gross LSOC

Fee €3,500 €3,500 €3,5001 $0
CORPORATE

1

Gross OSA account charges:

 Main value segregated collateral account operated by the Clearing Member, only one per

Clearing Member. The main Gross OSA1 is charged at €0/€0.

 Each additional Gross OSA will be charged at €1,750 for each 6‐month period (comparison

annual cost €3,500)

Onboarding Fees

A €15k one‐off onboarding fee will be charged per Legal Entity under the Introductory tariff or per

Financial Group of a Clearing Member under the Unlimited tariff, applicable for new onboardings

starting in 2024 (application file received after January 1st, 2024).

Options Tariff  

General

Member

  

Introductory Tariff Can cover either one or multiple legal entities under conditions below

(no Affiliate coverage)

In‐year switches are not permitted

No EEP usage fees in 20232024

Clearing Fees $8   per million of option notional on US Indices

€8 per million of option notional on European

Indices

Floor on clearing fees,

charged 1/12th for each

month a Member

Group is live 

€115k Per calendar year (no pro‐rating) for 1 entity

€150k Per calendar year (no pro‐rating) for 2 entities of

the same Financial Group of a Clearing Member  

€190k Per calendar year (no pro‐rating) for 3 or more

entities of the same Financial Group of a Clearing

Member  

Unlimited Tariff Cover all Affiliates of a given Financial Group of a Clearing Member   

Cover all clearing fees for Credit Option House activity for both iTraxx®

and CDXTM.NA underlying index families  

In‐year switches are not permitted

No EEP usage fees in 20232024

Fixed fee (annual),

charged 1/12th for each

€375k Per calendar year (no pro‐rating)
CORPORATE

month a Member

Group is live** **

Discounted Rates €115k if notionals cleared strictly above €15bn and the Member Group

is live for the whole calendar year (January 1st – December 31st), the

Clearing House will provide a €260k rebate in the December bill

New Market

Participant Tariff

Can apply to either one or multiple legal entities under conditions

below (no affiliate coverage)

Available for new joiners only (i.e., no entity of the same Financial

Group of a Clearing Member registered to the Option clearing service

under the Introductory or the Unlimited tariff in the last 3 calendar

years), for 1 calendar year, renewable once only

In‐year switches are not permitted

No EEP usage fees in 20232024

€10 Per million notional on European Indices

$10 Per million notional on US Indices

Onboarding Fees

(both Introductory &

unlimited)

€30k 15k One‐off fee per Legal Entity under the

Introductory tariff or per Financial Group of a

Clearing Member under the Unlimited tariff.

Select Member Introductory Tariff Cover only one legal entity (no affiliate coverage)  

In‐year switches are not permitted

No EEP usage fees in 20232024

Clearing Fees $10 per million of option notional on US Indices

€10   per million of option notional on European

Indices

Unlimited Tariff Cover all Affiliates of a given Financial Group of a Clearing Member  

Cover all clearing fees for Credit Option House activity for both iTraxx®

and CDXTM.NA underlying index families

In‐year switches are not permitted

No EEP usage fees in 20232024

Fixed fee (annual),  

charged 1/12th for each

€400k Per calendar year (no pro‐rating)
CORPORATE

Client Options Clearing Fees   $4 per million of option notional on US Indices  

    €4 per million of option notional on European

Indices  

    20232024: Full discount of client variable fees

CCP switch Incentive Programme  CCP switch programme now available to market participants

and applicable to live CCP trades only from January 1st, 2024,

onwards.

 Members and Clients can benefit from the programme by

closing out existing CDS transactions at their current CDS CCP

and clearing new transactions at LCH SA CDSClear.

 After registration, no variable fees will be charged for new

transactions cleared at LCH SA CDSClear under the Programme

during a 6‐month period and a credit note will be applied to

Members’ and Clients’ clearing accounts, covering the fees

associated with closing out positions at another CDS CCP. The

credit note will be applicable towards fees associated with

future transactions cleared at LCH SA CDSClear.

 The amount of the credit notes issued will be calculated using

the published variable fees at the Clients’ current CDS CCP.

High Turnover Fee plan The HTFP applies on the notional cleared in a calendar year but

excludes from the determination of the total cleared notional:

‐ the notional cleared for which a CCP Switch credit note was

used to zero out the clearing fees  

‐ the notional cleared part of a CCP Switch that thus did n’ot

attract any clearing fees

‐ the trades not charged under the Intraday Trading Fee Plan

or the CC Switch Programme

Options are excluded from the High Turnover Fee plan

month a Member is

live****

Discounted Rates €115k if notionals cleared strictly above €15bn and the Member is live

for the whole calendar year (January 1st – December 31st), the Clearing

House will provide a €285k rebate in the December bill

Onboarding Fees (both

Introductory & unlimited

€30k 15k One‐off fee per Legal Entity under the

Introductory tariff or per Financial Group of a

Clearing Member under the Unlimited tariff  
CORPORATE

The High Turnover Fee plan does not apply to General Members

Bucket 1 €4 per million of EUR Indices gross notional cleared if the total

annual gross notional cleared of EUR Indices is strictly below

€60billion

€12 per million of EUR Single Names gross notional cleared if the

total annual gross notional cleared of EUR Single Names is strictly

below €5billion

$5 per million of USD Indices gross notional cleared if the total

annual gross notional cleared of USD Indices is strictly below

$60billion

$17 per million of USD Single Names gross notional cleared if the

total annual gross notional cleared of USD Single Names is strictly

below $5billion

Bucket 2 €3 per million of EUR Indices gross notional cleared if the total

annual gross notional cleared of EUR Indices is above €60billion and

strictly below €120billion

€9 per million of EUR Single Names gross notional cleared if the

total annual gross notional cleared of EUR Single Names is above

€5billion and strictly below €10billion

$4 per million of USD Indices gross notional cleared if the total

annual gross notional cleared of USD Indices is above $60billion and  

strictly below $120billion

$12 per million of USD Single Names gross notional cleared if the

total annual gross notional cleared of USD Single Names is above

$5billion and strictly below $10billion

Bucket 3 €2 per million of EUR Indices gross notional cleared if the total

annual gross notional cleared of EUR Indices is above €120billion

and strictly below €240billion

€6 per million of EUR Single Names gross notional cleared if the

total annual gross notional cleared of EUR Single Names is above

€10billion and strictly below €20billion

$3 per million of USD Indices gross notional cleared if the total

annual gross notional cleared of USD Indices is above $120billion

and strictly below $240billion
CORPORATE

$7 per million of USD Single Names gross notional cleared if the

total annual gross notional cleared of USD Single Names is above

$10billion and strictly below $20billion

Bucket 4 €1 per million of EUR Indices gross notional cleared if the total

annual gross notional cleared of EUR Indices is above €240billion

and strictly below €480billion

€3 per million of EUR Single Names gross notional cleared if the

total annual gross notional cleared of EUR Single Names is above

€20billion and strictly below €40billion

$2 per million of USD Indices gross notional cleared if the total

annual gross notional cleared of USD Indices is above $240billion

and  strictly below $480billion

$2 per million of USD Single Names gross notional cleared if the

total annual gross notional cleared of USD Single Names is above

$20billion and strictly below $40billion

Bucket 5 Free of charge if the total annual EUR Indices gross notional cleared

of EUR Indices is above €480billion

Free of charge if the total annual EUR Single Names gross notional

cleared of EUR Single Names is above €40billion

Free of charge if the total annual USD Indices gross notional cleared

of USD Indices is above $480billion

Free of charge if the total annual USD Single Names gross notional

cleared of USD Single Names is above $40billion

Affiliates clearing as Client (all products)

Affiliates

clearing as

Clients

Full rebate on variable clearing fees for the Affiliate of a Clearing Member onboarded as client of

such Clearing Member under the following conditions:

 The Clearing Member is a General Member under the Unlimited Tariff;

 The Affiliate is a legal entity part of the same Financial Group as the Clearing Member;

 The rebate applies to 1 trade account per affiliate and for all clearing services for which

the Clearing Member is under the Unlimited Tariff (i.e.i.e., Index & Single Names and/or

Options);

 The rebate cannot apply to any account opened for CCM Indirect Clients; and

A fixed annual account fee of €100,000 is charged per affiliate of a Clearing Member

onboarded as a client and benefiting from the full rebate on variable fees.

* Subject to any appropriate regulatory review and/or approval process duly completed