SEC Division of Trading and Markets no-action letter: Letter from LSE Derivatives

Morgan Lewis
Ignacio Sandoval
Partner
+1.202.739.5201 ignacio.sandoval@morganlewis.com June 3, 2019 VIA E-MAIL AND FEDERAL EXPRESS Brett Redfearn Director Division of Trading and Markets U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Reliance by London Stock Exchange Derivatives Market on No-Action Relief for Foreign Options Markets and their Members that Engage in Familiarization Activities Dear Mr. Redfearn:
On November 12, 2014, on behalf of the London Stock Exchange Derivatives Market ['Exchange''), we submitted, to the then director and staff of the Securities and Exchange Commission's ("SEC") Division of Trading and Markets (''Staff"), a notification1 regarding the Exchange's intent to rely on the class no-action relief issued for foreign options markets and their members that engage in familiarization activities (as defined in the Class Relief). 2 At the request of the Exchange, we are now writing to notify you that, as of the close of the Exchange's business day on June 21, 2019 ("End Date"), the Exchange and its members will no longer rely on the Class Relief to engage in familiarization activities for the product types described in the Notification. This is because, after the close of business on the End Date, the Exchange will no longer list the products types that were the subject of the Notification. While the Exchange and its members will no longer engage in familiarization activities, we note that any outstanding positions in products at the close of the business on the End Date (and in reliance on the Notification) will be cash settled. Further, the Exchange understands that if it sought to engage in familiarization activities again in the future, it would have to submit a new notification letter pursuant to the requirements of the Class Relief.

---

See London Stock Exchange Derivatives Market, SEC No-Action Letter (Nov. 12, 2014) (''Notification''). See LIFFE A&M and Class Relief, SEC No-Action Letter (Jul. 1, 2013) (''Class Relief"). Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 0 +1.202.739.3000 United States 0 +1.202.739.3001 D81/ 104232945.3 2

Morgan Lewis
Brett Redfearn
U.S. Securities and Exchange Commission
June 3, 2019
We would be pleased to answer any questions that you or the Staff may have regarding this letter. Please feel free to contact me through the contact information listed above, or Jon Farrimond, Rules and Compliance Manager, +44(0) 207797 1886, jfarrimond@lseg.com. cc:
Richard Holley III, Assistant Director, SEC
Michael M. Philipp, Morgan, Lewis and Beckius LLP D81/ 104232945.3