EXHIBIT A-1

DCO CORE PRINCIPLES COMPLIANCE CHART

Attach as Exhibit A-1, a regulatory compliance chart setting forth each Core Principle and providing citations to the Applicant’s relevant rules, 

policies, and procedures that address each Core Principle, and a brief summary of the manner in which Applicant will comply with each Core 

Principle.

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

CORE PRINCIPLE A -

COMPLIANCE

(i) IN GENERAL. To be registered and 

to maintain registration as a derivatives 

clearing organization, a derivatives 

clearing organization shall comply with 

each core principle described in this 

paragraph and any requirement that the 

Commission may impose by rule or 

regulation pursuant to section 8a(5).

(ii) DISCRETION OF DERIVATIVES 

CLEARING ORGANIZATION. 

Subject to any rule or regulation 

prescribed by the Commission, a 

derivatives clearing organization shall 

have reasonable discretion in 

establishing the manner by which the 

derivatives clearing organization 

complies with each core principle 

described in this paragraph.

The Clearinghouse has applied for 

registration as a derivative clearing 

organization (“DCO”) by submitting 

Form DCO (the “Application”) and the 

required exhibits. Once registered, the 

Clearinghouse will comply with the 

DCO Core Principles set forth in the 

Commodity Exchange Act (“CEA”) and 

all applicable rules of the Commodity 

Futures Trading Commission 

(“Commission” or “CFTC”). 

As demonstrated in its Application, the 

Clearinghouse has implemented 

policies, procedures and controls that 

include, among others, a Compliance 

Policies and Procedures Manual (the 

“Manual”), Business Continuity Plan, 

Risk Management Policy, Code of 

Conduct, Settlement Policy, Treasury 

Policy and Procedures, Financial 

Resources Reporting Policy, and other 

information security policies 

(“Operational Policies”), as well as the 

DCO’s Rulebook (the “Rules”) and 

CEA Section 5b(c)(2)(A)

This Application, including all 

exhibits and attachments.
2

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

other policies and procedures designed 

to instruct the activities of Clearing

Members, directors, officers, and 

employees. In addition, the Operational 

Policies and the Rules have been 

designed to ensure the Clearinghouse’s

compliance with the CEA and CFTC’s 

rules.

Capitalized terms that are used in this

Exhibit A-1 without definition have the 

meaning ascribed to those terms in the

Rules.

CORE PRINCIPLE B – FINANCIAL

RESOURCES

(i) IN GENERAL. Each derivatives

clearing organization shall have

adequate financial, operational, and

managerial resources, as determined by 

the Commission, to discharge each 

responsibility of the derivatives clearing 

organization.

(iii) MINIMUM AMOUNT OF 

FINANCIAL RESOURCES. Each

derivatives clearing organization shall 

possess financial resources that, at a 

minimum, exceed the total amount that 

would –

(I) enable the organization to meet its 

financial obligations to its members and 

participants notwithstanding a default 

The Clearinghouse will maintain 

sufficient financial, operational, and 

managerial resources to discharge each 

responsibility of the DCO. 

The Clearinghouse will maintain a 

guaranty fund and will maintain

sufficient financial resources to meet its 

financial obligations notwithstanding a 

default by any Clearing Member. In 

addition, the Clearinghouse will 

maintain sufficient financial resources 

to cover the operating costs of the DCO 

for a period of one year (as calculated 

on a rolling basis). The Clearinghouse’s

CFO and other finance personnel 

possess knowledge of the CFTC’s 

financial resources requirements to 

enable the Clearinghouse to satisfy the 

CEA Section 5b(c)(2)(B)

All exhibits filed under B-1, B-2, B-3 

and B-4

Exhibit B-2(5)(a) - Clearinghouse 

Guaranty Fund Policies & 

Procedures

Financial Statements
3

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

by the member or participant creating 

the largest financial exposure for that 

organization in extreme but plausible 

market conditions; and

(II) enable the derivatives clearing 

organization to cover the operating costs 

of the derivatives clearing organization 

for a period of 1 year (as calculated on a 

rolling basis).

CFTC’s financial resources 

requirements.

As set forth in the Operational Policies, 

the Clearinghouse will report the DCO’s 

financial resources to the CFTC.

CORE PRINCIPLE C –

PARTICIPANT AND PRODUCT 

ELIGIBILITY

(i) IN GENERAL. Each derivatives 

clearing organization shall establish –

(I) appropriate admission and 

continuing eligibility standards 

(including sufficient financial resources 

and operational capacity to meet 

obligations arising from participation in 

the derivatives clearing organization) 

for members of, and participants in, the 

derivatives clearing organization; and 

(II) appropriate standards for 

determining the eligibility of 

agreements, contracts, and transactions 

submitted to the derivatives clearing 

organization for clearing.

(ii) REQUIRED PROCEDURES. 

Each derivatives clearing organization 

shall establish and implement 

The Clearinghouse has established 

transparent and objective Clearing 

Member eligibility criteria that allows 

for open access to the Clearinghouse. 

The eligibility criteria is set forth in 

Chapter 3 of the Rules.

All Persons must satisfy an application 

process to become approved as a 

Clearing Member and comply with all 

Rules.

Any violation of the Rules may result in 

a Disciplinary Action against the 

relevant Clearing Member. As specified 

in Chapter 6 of the Rules, the 

Clearinghouse maintains the ability to 

suspend, sanction and otherwise 

discipline Clearing Members who 

violate any Rule.

In addition, as set forth in the

Clearinghouse’s Compliance Policies 

and Procedures Manual, the 

CEA Section 5b(c)(2)(C)(i)(I)

Exhibit C-1(1) - Clearing Member 

Agreement 

Chapter 3 of the Rules; Rules 802; 

803

CEA Section 5b(c)(2)(C)(i)(II)

Exhibits C-1 and C-2

Rule 502

Exhibit C-2(a) - Product Listing 

Requirement Policies

CEA Section 5b(c)(2)(C)(ii)

Exhibits C-1 and C-2

Exhibit C-1(5)-Monitoring the 

Financial Status of Clearing 

Members

Exhibit C-1(1) - Clearing Member 

Agreement 
4

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

procedures to verify, on an ongoing 

basis, the compliance of each 

participation and membership 

requirement of the derivatives clearing 

organization.

(iii) REQUIREMENTS. The 

participation and membership 

requirements of each derivatives

clearing organization shall –

(I) be objective;

(II) be publicly disclosed; and

(III) permit fair and open access.

Clearinghouse has established a product 

review process for determining 

eligibility of agreements, contracts, or 

transactions submitted to the 

Clearinghouse for clearing.

CEA Section 5b(c)(2)(C)(iii) 

Exhibits C-1 and C-2 

Exhibit C-1(1) - Clearing Member 

Agreement

The Clearinghouse website has a 

publicly disclosed rulebook.

CORE PRINCIPLE D – RISK

MANAGEMENT

(i) IN GENERAL.—Each derivatives 

clearing organization shall ensure that 

the derivatives clearing organization 

possesses the ability to manage the risks 

associated with discharging the 

responsibilities of the derivatives 

clearing organization through the use of

appropriate tools and procedures.

(ii) MEASUREMENT OF CREDIT

EXPOSURE.—Each derivatives

clearing organization shall—

(I) not less than once during each

business day of the derivatives clearing 

organization, measure the credit 

The Clearinghouse intends to operate 

under a traditional clearing model in 

which Clearing Members will be 

required to be futures commission 

merchants (“FCMs”) registered and in 

good standing with the CFTC.

The Clearinghouse Risk Management 

Program includes:

• governance overseen by the 

Risk Committee, which is part 

of the Board;

• Clearing Member application 

process to ensure the applicants 

have sufficient capital, liquidity, 

and experience to clear the 

products being offered;

CEA Section 5b(c)(2)(D)

All exhibits filed under D-1, D-2, D3 and D-4

Chapter 8 of the Rules

Exhibit C-1(5) - Monitoring the 

Financial Status of Clearing 

Members

Exhibit G - Default Rules and 

Procedures

Exhibit G(a) - Default Management 

Plan
5

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

exposures of the derivatives clearing 

organization to each member and 

participant of the derivatives clearing 

organization; and

(II) monitor each exposure described in 

subclause (I) periodically during the 

business day of the derivatives clearing

organization.

(iii) LIMITATION OF EXPOSURE TO

POTENTIAL LOSSES FROM

DEFAULTS.—Each derivatives

clearing organization, through margin 

requirements and other risk control 

mechanisms, shall limit the exposure of 

the derivatives clearing organization to 

potential losses from defaults by 

members and participants of the 

derivatives clearing organization to 

ensure that—

(I) the operations of the derivatives

clearing organization would not be

disrupted; and (IV) non-defaulting 

members or participants would not be 

exposed to losses that non-defaulting

members or participants cannot 

anticipate or control.

(iv) MARGIN REQUIREMENTS.—

The margin required from each member 

and participant of a derivatives clearing 

organization shall be sufficient to cover 

• A margin methodology that 

provides Margin requirements 

based on the historical volatility 

of the products and the use of 

PC-SPAN for Clearing 

Members to leverage an 

industry available margin 

system that already interacts 

with back office systems; and

• a Guaranty Fund that is funded 

by the Clearinghouse but has 

assessment powers if required.

Exhibit F-3(1) - Investment 

Standards Policy

Exhibit O(a)(2-4) - Risk Committee 

Charter
6

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

potential exposures in normal market 

conditions.

(v) REQUIREMENTS REGARDING

MODELS AND PARAMETERS.—

Each model and parameter used in 

setting margin requirements under 

clause (iv) shall be—

(I) risk-based; and

(II) reviewed on a regular basis.

CORE PRINCIPLE E -

SETTLEMENT

PROCEDURES

Each derivatives clearing organization 

shall—

(i) complete money settlements on a

timely basis (but not less frequently

than once each business day); 

(ii) employ money settlement 

arrangements to eliminate or strictly 

limit the exposure of the derivatives 

clearing organization to settlement bank 

risks (including credit and liquidity risks 

from the use of banks to effect money 

settlements);

(iii) ensure that money settlements are 

final when effected;

The Clearinghouse maintains regular 

daily settlement procedures to ensure 

that completes settlements on a timely 

basis (no less frequently than once 

daily). All settlements are final when 

effected, and the Clearinghouse

maintains records of all flow of funds 

associated with all settlements.

The Clearinghouse maintains policies 

and procedures to ensure that it enters 

into settlement arrangements only with 

financial institutions that meet certain 

credit and operational criteria.

CEA Section 5b(c)(2)(E)(i)

Exhibits E-1, E-2 and E-3

Rule 509

CEA Section 5b(c)(2)(E)(ii)

Exhibits E-1, E-2 and E-3

Rule 813

CEA Section 5b(c)(2)(E)(iii)

Exhibits E-1, E-2 and E-3

Rule 509; 

CEA Section 5b(c)(2)(E)(iv)

Exhibits E-1, E-2 and E-3

Section 8 of the Recordkeeping
7

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

(iv) maintain an accurate record of the 

flow of funds associated with each 

money settlement;

(v) possess the ability to comply with 

each term and condition of any 

permitted netting or offset arrangement 

with any other clearing organization;

(vi) regarding physical settlements, 

establish rules that clearly state each 

obligation of the derivatives clearing 

organization with respect to physical 

deliveries; and

(vii) ensure that each risk arising from 

an obligation described in clause (vi) is 

identified and managed.

Exhibit K(a) - Recordkeeping 

Policies

Exhibit K(b) - Recordkeeping 

Procedures

CEA Section 5b(c)(2)(E)(v)

Exhibits E-1, E-2 and E-3

CEA Section 5b(c)(2)(E)(vi)

Exhibits E-1, E-2 and E-3

Rule 1102 Participant and Clearing 

Member Delivery Obligations

CEA Section 5b(c)(2)(E)(vii)

Exhibits E-1, E-2 and E-3 

Chapter 11 Digital Asset Delivery in 

general, and Rules

CORE PRINCIPLE F -

TREATMENT OF FUNDS

(i) REQUIRED STANDARDS AND 

PROCEDURES – Each derivatives

clearing organization shall establish

standards and procedures that are

designed to protect and ensure the

safety of member and participant funds 

and assets.

(ii) HOLDING OF FUNDS AND 

ASSETS – Each derivatives clearing

The Clearinghouse has established 

policies and procedures that are 

designed to protect and ensure the 

safety of Clearing Member, Participant

and Customer funds and assets, 

including Margin, while mitigating risks 

and employing industry best practices 

and safeguards.

Rule 304 provides that Clearing

Member funds and assets, including

CEA Section 5b(c)(2)(F)(i)

Exhibits F-1, F-2 and F-3

Rule 304

Exhibit D-4 – Collateral

Exhibit F-3(1) - Investment 

Standards Policy
8

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

organization shall hold member and

participant funds and assets in a manner 

by which to minimize the risk of loss or 

of delay in the access by the derivatives 

clearing organization to the assets and 

funds.

(iii) PERMISSIBLE INVESTMENTS –

Funds and assets invested by a 

derivatives clearing organization shall 

be held in instruments with minimal 

credit, market, and liquidity risks.

Margin, shall be segregated and treated 

as belonging to Clearing Members.

Funds and assets, including Margin, of 

Clearing Members will be held in 

segregated Customer Accounts, while

Customer Margin will be held in 

accordance with the CEA and CFTC

Rule 1.20 in an account identified as 

“Customer Segregated.” Both member 

property accounts and Customer 

Accounts will remain segregated from 

the Clearinghouse’s operating funds.

The Clearinghouse maintains internal 

settlement bank selection criteria and 

periodically monitors each settlement 

bank to ensure that the bank(s) 

continues to satisfy the criteria.

The Clearinghouse maintains rules to 

ensure that any action taken with 

respect to Clearing Member and 

Customer funds and assets is carefully 

monitored and subject to multiple layers 

of oversight and/or approval.

Funds and assets belonging to 

Customers that are invested by the 

Clearinghouse will be held in 

instruments that comply with CFTC

Rules 1.25 and 39.15(e). Non-Customer 

funds and assets belonging to Clearing

Members that are invested by the 

Clearinghouse will be held in 

CEA Section 5b(c)(2)(F)(ii)

Exhibits F-1, F-2 and F-3

Exhibit D-4 – Collateral

Exhibit F-3(1) - Investment 

Standards Policy

CEA Section 5b(c)(2)(F)(iii)

Exhibits F-1, F-2 and F-3

Rules 819; 820

Exhibit D-4 – Collateral

Exhibit F-3(1) - Investment 

Standards Policy
9

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

instruments that comply with CFTC 

Rule 39.15(e).

CORE PRINCIPLE G - DEFAULT

RULES AND PROCEDURES

(i) IN GENERAL – Each derivatives 

clearing organization shall have rules 

and procedures designed to allow for 

the efficient, fair, and safe management 

of events during which members or 

participants— 

(I) become insolvent; or

(II) otherwise default on the

obligations of the members or

participants to the derivatives clearing 

organization.

(ii) DEFAULT PROCEDURES – Each 

derivatives clearing organization shall—

(I) clearly state the default procedures 

of the derivatives clearing organization;

(II) make publicly available the default 

rules of the derivatives clearing 

organization; and

(III) ensure that the derivatives clearing 

organization may take timely action—

(aa) to contain losses and liquidity 

pressures; and

The Rules define and address defaults, 

which include Clearing Member 

insolvency and a failure to satisfy 

obligations owed to the Clearinghouse.

The Rules related to default risk 

management are designed to reduce the 

likelihood of a Clearing Member 

Default and the potential for a material

disruption to the market and other 

Clearing Members. 

In addition, the Clearinghouse’s default 

procedures supplement the Rules.

CEA Section 5b(c)(2)(G)

Chapter 8 of the Rules

Rule 814

Exhibit D-1 - Risk Management 

Program

Exhibit D-2(4) - Margin 

Methodology

Exhibit C-1(5)-Monitoring the 

Financial Status of Clearing 

Members

Exhibit G - Default Rules and 

Procedures

Exhibit G(a) - Default Management 

Plan

Exhibit G(d) - Process to Address 

Shortfalls
10

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

(bb) to continue meeting each obligation 

of the derivatives clearing organization.

CORE PRINCIPLE H – RULE

ENFORCEMENT

Each derivatives clearing organization 

shall—

(i) maintain adequate arrangements and 

resources for—

(I) the effective monitoring and

enforcement of compliance with the

rules of the derivatives clearing

organization; and

(II) the resolution of disputes;

(ii) have the authority and ability to

discipline, limit, suspend, or terminate 

the activities of a member or participant 

due to a violation by the member or 

participant of any rule of the derivatives 

clearing organization; and

(iii) report to the Commission regarding 

rule enforcement activities and 

sanctions imposed against members and 

participants as provided in clause (ii).

The Clearinghouse has the authority and 

ability to enforce its Rules. Pursuant to 

Rule 301, any Person initiating or

executing a transaction in contracts to

be cleared by the Clearinghouse, and 

any Person for whose benefit such a 

transaction has been initiated or 

executed, expressly consents to the 

jurisdiction of the Clearinghouse and 

agrees to be bound by and comply with 

the Rules of the Clearinghouse in 

relation to such transactions and

contracts, including, but not limited to, 

rules requiring cooperation and

participation in investigatory and

disciplinary processes.

The Clearinghouse’s Compliance 

Department monitors the Clearinghouse

market and evaluates Clearing for

Clearing Members ongoing eligibility 

under the Rules of the Clearinghouse,

specifically with respect to Chapter 8,

which outlines, in part, ongoing

responsibilities of Clearing Members

and financial requirements of FCM

Clearing Members. 

Chapter 6 sets forth in a transparent 

manner the disciplinary procedures to 

which the Clearinghouse adheres in the 

CEA Section 5b(c)(2)(H)(ii)

Exhibit H

Rule 601

Chapter 6 of the Rules 

Exhibit A-11(g) - Bitnomial 

Compliance Manual

Exhibit A-11(g-1) - Investigation and 

Enforcement Procedure

CEA Section 5b(c)(2)(H)(iii)

Exhibit H

Chapter 7 of the Rules

Exhibit A-11(g-3) - Enforcement 

Notification Procedure
11

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

event that a Clearing Member is 

suspected of violating Clearinghouse 

rules. The Compliance Department is 

responsible for investigating and 

prosecuting suspected Rule violations.

Chapter 7 of the Rules sets forth dispute 

resolution requirements for certain 

disputes between Clearing Members or

disputes involving Customers.

CORE PRINCIPLE I – SYSTEM

SAFEGUARDS

Each derivatives clearing organization 

shall—

(i) establish and maintain a program of 

risk analysis and oversight to identify 

and minimize sources of operational 

risk through the development of 

appropriate controls and procedures, 

and automated systems, that are reliable, 

secure, and have adequate scalable

capacity;

(ii) establish and maintain emergency 

procedures, backup facilities, and a plan 

for disaster recovery that allows for—

(I) the timely recovery and resumption 

of operations of the derivatives clearing 

organization; and

The Clearinghouse will utilize the 

information technology resources of the 

Exchange, which have been robustly 

developed through operational testing

over the past seven years.

The Clearinghouse continually monitors 

for actual or threatened risks. The 

Clearinghouse’s technology systems 

offer security to prevent system outages 

and cyber-attacks. The Clearinghouse’s

technology staff conducts periodic 

audits to verify the integrity of the 

Clearinghouse’s technology systems.

The Clearinghouse maintains policies 

and procedures designed to identify and 

reduce operational and technological 

risk, and senior management meet

together on frequent basis to discuss

implementation and remediation plans.

Senior management will submit reports

to the Risk Management Committee, 

CEA Section 5b(c)(2)(I)(i)

Exhibits I(a), I(b), I(c), I(d), I(e), I(f), 

I(g), I(h), I(i), I(j), I(k), and I(l)

Exhibit A-11(g-2) Market 

Suspension and Emergency 

Procedures

Exhibit D-1 - Risk Management 

Program

Exhibit D-2(4) - Margin 

Methodology

Exhibit C-1(5) - Monitoring the 

Financial Status of Clearing 

Members

CEA Section 5b(c)(2)(I)(ii)

Exhibits I(a), I(b), I(c), I(d), I(e), I(f), 

I(g), I(h), I(i), I(j), I(k), and I(l)

Rule 512
12

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

(II) the fulfillment of each obligation 

and responsibility of the derivatives 

clearing organization; and

(iii) periodically conduct tests to verify 

that the backup resources of the 

derivatives clearing organization are 

sufficient to ensure daily processing, 

clearing, and settlement.

which is responsible for overseeing

firm-wide risk and advising officers on 

procedures to detect and prevent risks.

The Clearinghouse has established a 

Business Continuity Plan to be activated 

in the event of an emergency or other

circumstances warranting activation of 

such plan. As set forth in the Business

Continuity Plan, the Clearinghouse

maintains emergency procedures and 

backup facilities to provide for the 

timely recovery and resumption of 

operations of the Clearinghouse in event 

of an emergency.

Additionally, the Clearinghouse will 

maintain policies and procedures to 

provide for operational redundancy.

Internal operational procedures are set 

forth in a comprehensive manner in the

Operational Policies. Finally, the 

Clearinghouse’s managerial resources 

are sufficient to perform the functions 

of each vital area of the DCO, with 

appropriate cross-training to ensure that 

resources will remain satisfactory in the 

event of an absence or unavailability.

CEA Section 5b(c)(2)(I)(iii)

Exhibits I(a), I(b), I(c), I(d), I(e), I(f), 

I(g), I(h), I(i), I(j), I(k), and I(l)

CORE PRINCIPLE J -

REPORTING

Each derivatives clearing organization 

shall provide to the Commission all 

The Clearinghouse will submit to the 

CFTC all required reports, including 

daily open interest and other contractspecific information reports, and 

quarterly and annual financial reports. 

CEA Section 5b(c)(2)(J)

Exhibit J(a) - Reporting Policies

Exhibit J(b) - Reporting Procedures
13

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

information that the Commission 

determines to be necessary to conduct 

oversight of the derivatives clearing

organization.

The Clearinghouse’s Chief Compliance 

Officer will submit an annual 

compliance report as required by CFTC

Rule 39.10.

The Compliance Policies and

Procedures Manual sets forth internal 

procedures for compliance with 

reporting obligations and all 

departments are aware of applicable 

reporting obligations.

Exhibit A-11(g-5) - CFTC Daily 

Reporting Procedure

Exhibit A-11(g-6) - Daily Financial 

Review Procedure

Website (www.bitnomial.com)

CFTC Reporting Templates

CORE PRINCIPLE K -

RECORDKEEPING

Each derivatives clearing organization 

shall maintain records of all activities 

related to the business of the derivatives 

clearing organization as a derivatives

clearing organization—

(i) in a form and manner that is

acceptable to the Commission; and

(ii) for a period of not less than 5

years.

The Clearinghouse’s Recordkeeping 

Policy describes the Clearinghouse’s 

recordkeeping program, which is

compliant with CFTC Rule 1.31. In 

addition, Rule 208, provides that the 

Clearinghouse will keep, or cause to be 

kept, complete and accurate books and 

records of accounts of the 

Clearinghouse, including, without 

limitation, all books and records 

required to be maintained pursuant to 

the CEA, and the CFTC Rules. The 

Clearinghouse will retain all such books 

and records for at least five years, and 

shall make such books and records 

readily accessible for inspection by the 

CFTC and the U.S. Department of 

Justice.

CEA Section 5b(c)(2)(K)

Exhibit K

Recordkeeping Policy 

Rule 208

Exhibit A-11(g-7) - Bitnomial 

Internal Audit Trail

CORE PRINCIPLE L – PUBLIC

INFORMATION

The Clearinghouse will make certain

information public through its website 

CEA Section 5b(c)(2)(L)
14

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

(i) IN GENERAL – Each derivatives 

clearing organization shall provide to 

market participants sufficient

information to enable the market 

participants to identify and evaluate 

accurately the risks and costs associated 

with using the services of the 

derivatives clearing organization.

(ii) AVAILABILITY OF 

INFORMATION

-Each derivatives clearing organization 

shall make information concerning the 

rules and operating and default 

procedures governing the clearing and 

settlement systems of the derivatives 

clearing organization available to 

market participants.

(iii) PUBLIC DISCLOSURE – Each 

derivatives clearing organization shall 

disclose publicly and to the Commission 

information concerning—

(I) the terms and conditions of each 

contract, agreement, and transaction 

cleared and settled by the derivatives 

clearing organization;

(II) each clearing and other fee that the 

derivatives clearing organization 

charges the members and participants of 

the derivatives clearing organization;

as required by CFTC rules. The 

Clearinghouse’s procedures for making 

information public are incorporated in 

the Operational Policies.

Exhibit L

Public Exhibit L-1 – Public 

Information Policy

Website (www.bitnomial.com)
15

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

(IV) the margin-setting methodology, 

and the size and composition, of the 

financial resource package of the 

derivatives clearing organization;

(V) daily settlement prices, volume, 

and open interest for each contract 

settled or cleared by the derivatives 

clearing organization; and

(VI) any other matter relevant to 

participation in the settlement and 

clearing activities of the derivatives

clearing organization.

CORE PRINCIPLE M -

INFORMATION-SHARING

Each derivatives clearing organization 

shall—

(i) enter into, and abide by the terms 

of, each appropriate and applicable 

domestic and international informationsharing agreement; and

(ii) use relevant information obtained 

from each agreement described in 

clause (i) in carrying out the risk 

management program of the derivatives 

clearing organization.

The Clearinghouse has not entered into

any information sharing agreements 

(domestic or international) with entities 

besides those between the Exchange and 

the Clearinghouse.

CEA Section 5b(c)(2)(M)

Exhibit M

Rule 209

CORE PRINCIPLE N –

ANTITRUST CONSIDERATIONS

The Clearinghouse promotes a culture 

of compliance, including compliance 

CEA Section 5b(c)(2)(N)

Exhibit N
16

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

Unless necessary or appropriate to 

achieve the purposes of this chapter, a 

derivatives clearing organization shall 

not—

(i) adopt any rule or take any action that 

results in any unreasonable

restraint of trade; or

(ii) impose any material 

anticompetitive burden.

with antitrust laws and Core Principle 

N.

The Clearinghouse will not adopt rules 

or take other actions that result in 

unreasonable restraint of trade or 

impose any material anticompetitive 

burden unless such action is appropriate 

to achieve the purposes of the Act. Prior 

to adopting any new or revised rule, or 

when taking other actions, The 

Clearinghouse’s Legal Department will 

consider, as appropriate, whether such 

rule or action is the least 

anticompetitive means of achieving its 

objective.

Exhibit A-11(e) - Clearinghouse 

Code of Business Conduct and Ethics

Exhibit N-1 Antitrust Policy

CORE PRINCIPLE O –

GOVERNANCE FITNESS 

STANDARDS

(i) GOVERNANCE 

ARRANGEMENTS – Each derivatives 

clearing organization shall establish 

governance arrangements that are

transparent—

(I) to fulfill public interest requirements; 

and

(II) to permit the consideration of the 

views of owners and participants.

(ii) FITNESS STANDARDS – Each

derivatives clearing organization shall 

The Clearinghouse has established 

governance arrangements that are 

transparent and that fulfill the 

requirements imposed by the CEA and 

the CFTC’s rules promulgated 

thereunder. 

The Board will be comprised of three

directors, including at least 35% of 

whom shall be Public Directors. 

Directors, officers and disciplinary

committee members must satisfy

eligibility criteria as set forth in Rule 

202. Conflicts of interest are addressed 

pursuant to Rule 207. All Clearinghouse

officers, employees and consultants are 

subject to a Code of Conduct policy that 

CEA Section 5b(c)(2)(O)(i)

Exhibit O

Exhibit O(a)(2-4) - Risk Committee 

Charter

CEA Section 5b(c)(2)(O)(ii)

Exhibit O

Rules 202, 203, 204, 205

Chapter 2 of the Rules

Exhibit A-11(e) - Clearinghouse 

Code of Business Conduct and Ethics
17

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

establish and enforce appropriate fitness 

standards for—

(I) directors;

(II) members of any disciplinary

committee;

(II) members of the derivatives

clearing organization;

(III) any other individual or entity with 

direct access to the settlement or 

clearing activities of the derivatives 

clearing organization; and

(VI) any party affiliated with any 

individual or entity described in this 

clause.

establishes standards of conduct for 

such individuals.

Clearing Members must satisfy

eligibility criteria as set forth in Chapter

8 of the Rules.

CORE PRINCIPLE P - CONFLICTS 

OF INTEREST

Each derivatives clearing organization 

shall—

(i) establish and enforce rules to 

minimize conflicts of interest in the

decision-making process of the

derivatives clearing organization; and

(ii) establish a process for resolving

conflicts of interest described in clause 

(i).

The Clearinghouse maintains policies 

related to conflicts of interest, including 

a conflicts of interest policy for 

directors, officers, committee members

and other Clearinghouse personnel that 

is set forth in the Rules. 

Specifically, Rule 207 describes the 

procedures to which an individual must 

adhere in the event such individual has a 

financial interest conflict or is a named 

party in interest in any matter that is 

before the individual for deliberation.

CEA Section 5b(c)(2)(P)

Exhibit P

Rule 207

Exhibit A-11(e) - Clearinghouse 

Code of Business Conduct and Ethics
18

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

CORE PRINCIPLE Q –

COMPOSITION OF GOVERNING 

BOARDS

Each derivatives clearing organization 

shall ensure that the composition of the 

governing board or committee of the 

derivatives clearing organization 

includes market participants.

The Clearinghouse ensures that the 

views of the public and market 

participants are incorporated into the 

Clearinghouse’s governance structure. 

The Clearinghouse has incorporated 

market participants into the governance 

structure, and at least one member of 

the Board must be affiliated with a 

market participant and one 

representative on the Risk Committee 

must be affiliated with a market 

participant.

Additionally, the Risk Committee must 

contain at least one independent 

participant.

CEA Section 5b(c)(2)(Q)

Exhibit Q

Risk Management Committee Charter

CORE PRINCIPLE R - LEGAL 

RISK

Each derivatives clearing organization 

shall have a well-founded, transparent, 

and enforceable legal framework for 

each aspect of the activities of the 

derivatives clearing organization.

The Clearinghouse has established an 

effective and enforceable legal 

framework. The Clearinghouse has 

entered into agreements with outside 

service providers for the provision of 

services that are essential to the 

Clearinghouse’s ability to perform 

clearing operations in compliance with 

the CEA and the CFTC’s rules 

promulgated thereunder. The 

Clearinghouse can lawfully enforce the 

Rules against Clearing Members.

Pursuant to Rule 301, any person 

initiating, executing, or benefiting from 

transactions cleared at the

Clearinghouse agrees to be bound by 

CEA Section 5b(c)(2)(R)

Rule 301

Chapter 8 of the Rulebook

Exhibit R

Exhibit C-1(1) - Clearing Member 

Agreement
19

Core Principle Brief Compliance Summary Citation(s) to Rules, Policies and/or 

Procedures

the Rules and the published policies of

the Clearinghouse and submits to the 

jurisdiction of the Clearinghouse. 

Additionally, anyone submitting an 

application to become a Clearing 

Member will be bound by the terms 

contained in the application. The Rules 

constitute a legally binding and 

enforceable agreement between the 

Clearinghouse and each Clearing 

Member.