EXHIBIT B
Redlined Rulebook

Redlined StreamGlobal Credit Default Swap Trading Platform Supplement

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4® Tradition _.

TRADITION SEF, Inc. Senior Regulatory Counsel and Secretary
Legal Department

March 29, 2018

VIA E-MAIL (submissions@cftc.gov)

Mr. Christopher Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: CFTC Regulation 40.6(a) Rule Certification.
Notification of Amendments to Tradition SEF, Inc. Rulebook and
StreamGlobal Credit Default Swap Trading Platform Supplement.
Tradition SEF Submission No. 2018-01.

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c) of the Commodity Exchange Act, as amended (the “Act”), and Commodity
Futures Trading Commission (“CFTC” or the “Commission”) Regulation 40.6(a), Tradition SEF, Inc.
(“Tradition SEF”) hereby notifies the Commission of amendments to the Tradition SEF Rulebook (the
“Rulebook”) and the StreamGlobal Credit Default Swap Trading Platform Supplement to the Rulebook
(the “Platform Supplement”), to be effective and implemented by Tradition SEF as of April 16, 2018.
Attached as Exhibit B are redlined versions of the Rulebook and Platform Supplement reflecting the
amendments described herein.

We have identified on Exhibit A amendments to Rule 541 of the Rulebook and Rule S3-104 of the
Platform Supplement and compliance with the SEF core principles (the “Core Principles”) as set forth in
Section Sh of the Act and Part 37 of the Commission’s regulations promulgated thereunder.

Tradition SEF continues to comply with the Core Principles. In particular, Tradition SEF has determined
that it is in compliance with Core Principle 1 (Compliance with Core Principles) and Core Principle 2
(Compliance with Rules), as further described in the compliance table provided in Exhibit A.

Tradition SEF hereby certifies that the rule amendments comply with the Act and the Commission’s
regulations promulgated thereunder. No substantive opposing views were expressed that were not
incorporated into the rule amendments. Tradition SEF hereby certifies that it has posted a notice of
pending certification with the Commission and a copy of the submission on its website (see,
http://www.traditionsef.com/regulatory/), concurrent with the filing of this submission with the
Commission.

Tradition SEF, Inc. 255 Greenwich Street, 4" floor, New York, NY 10007 F 2127914500 www.traditionsef.com


Should you require additional information related to this submission, please contact the undersigned at
(212) 377-2337 or scot.halvorsen@tradition.com. Please reference Tradition SEF Submission No. 2018-
01 in any related correspondence.

Sincerely,

Attachments: Exhibit A— Compliance with Core Principles table
Exhibit B — Tradition SEF Rulebook and Platform Supplement (redline format)


EXHIBIT A

Compliance with Core Principles

Rules

Rule Change

Explanation and Analysis of the operation,
purpose, and effect of the proposed rule or rule
amendment and its compliance with applicable
provisions of the Act, including core principles,
and the Commission’s regulations thereunder.

Tradition SEF
Rule 541

Tradition SEF amended Rule 541 to provide
consistency among Platforms regarding post-
trade name give-up for MAT Transactions.

The purpose of this Rule amendment is to
provide Participants and Customers certainty
when a party to a transaction executed on or
through Tradition SEF will be provided with the
other party’s relevant information. By
stipulating when counterparty identification
exchanges must occur, Tradition SEF continues
to comply with Core Principles 2 (Compliance
with rules) and 4 (Monitoring of trading and
trade processing) and CFTC Regulation 37.200(c),
which requires a SEF to “[e]stablish rules
governing the operation of the facility, including
rules specifying trading procedures to be used in
entering and executing orders traded or posted
on the facility, including block trades.”

Platform
Supplement
Rule S3-104

Tradition SEF amended Platform Supplement
Rule S3-104 to provide consistency among
Platforms regarding post-trade name give-up
for MAT Transactions.

The purpose of this Rule amendment is to
provide Participants and Customers certainty
when a party to a transaction executed on or
through Tradition SEF will be provided with the
other party’s relevant information. By
stipulating when counterparty identification
exchanges must occur, Tradition SEF continues
to comply with Core Principles 2 (Compliance
with rules) and 4 (Monitoring of trading and
trade processing) and CFTC Regulation 37.200(c),
which requires a SEF to “[e]stablish rules
governing the operation of the facility, including
rules specifying trading procedures to be used in
entering and executing orders traded or posted
on the facility, including block trades.”