AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

March 7, 2023

Submitted via Portal

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: 

CFTC Regulation 40.6(a) Required Certification AEGIS SEF, LLC

Amendment to Rulebook, Participant Agreement

Dear Sir:

Pursuant to Section 40.6(a) of the regulations of the U.S. Commodity Futures Trading 

Commission (the “CFTC”, or the “Commission”), AEGIS SEF, LLC (“AEGIS”) hereby notifies 

the Commission that it has amended its Rulebook and Participant Agreement. The Rule 

Amendments shall become effective 10 days after this submission has been filed or immediately 

upon approval by the CFTC, whichever occurs first.

A concise explanation and analysis of the rules and their compliance with applicable provisions 

of the Act, including core principles and the Commission’s regulations, is attached hereto as 

Exhibit A. A copy of the Rulebook is attached under separate cover as Exhibit B. A redlined 

version of the Rulebook is attached under separate cover as Exhibit C. A copy of the Participant 

Agreement is attached under separate cover as Exhibit D. A redlined version of the Participant 

Agreement is attached under separate cover as Exhibit E. Exhibits D and E bear the designation 

“Confidential Treatment Requested by AEGIS SEF, LLC.”

This request for confidential treatment is made pursuant to Commission Regulations 40.8, as 

Exhibits D and E contain information that would reveal the trade secrets or confidential 

commercial or financial information of AEGIS SEF and its affiliates.

AEGIS hereby certifies that: (i) the amended agreement complies with the Act and the

Commission’s regulations thereunder, and (ii) copy of this submission is being

concurrently posted on AEGIS’s website. There were no substantive opposing views to the

amendments to the Rulebook and Exhibit N-1.

Please contact the undersigned at 832-413-5973 or afurman@aegis-hedging.com with any 

questions regarding this matter.
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Andrew Furman

Chief Compliance Officer

AEGIS SEF, LLC

2829 Technology Forest Blvd

Suite 260

The Woodlands, TX 77381

Exhibit A – Explanation 

Amendment and Explanation Supporting Rule / Core Principle

Rulebook 4.8A.2: Execution Methods for 

SEF Contracts

• Enables two Participants to transact 

via the Offline Execution 

Functionality (OEF)

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2(A)- Terms, 

Conditions and Access to the Swap 

Execution Facility

Rulebook 4.18.4: Third-Party Reporting 

Under Parts 43 and 45

• Clarified Reporting Requirements

• Conformed SDR data references to 

December 5, 2022 updated formatting

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2 – Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• Core Principle 5 – Ability to Obtain 

Information

• Core Principle 10 – Recordkeeping

• Core Principle 15(B)(vi) – Establish 

Procedures for Remediation

• Part 43

• Part 45
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Rulebook 9.2.3: Market Data

• Clarifying market data rights

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

Participant Agreement: Clarifying 

reporting requirements for Participants 

who are Financial Counterparties

• Clarifying reporting requirements by 

which SDR is being reported to 

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2 – Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• Core Principle 5 – Ability to Obtain 

Information

• Core Principle 10 – Recordkeeping

• Part 43

• Part 45

Participant Agreement: Market Data

• Clarifying market data rights

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Exhibit B – AEGIS SEF Rulebook

(attached under separate cover)

Exhibit C – AEGIS SEF Rulebook (redlined)

(attached under separate cover)

Exhibit D – AEGIS SEF Participant Agreement

(attached under separate cover)

Exhibit E – AEGIS SEF Participant Agreement (redlined)

(attached under separate cover)