Thomson Reuters (SEF) LLC

3 Times Square

New York, NY 10036

August 10, 2018

Submitted Via Portal

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: Submission 18-02: Thomson Reuters (SEF) LLC – Amendments to Rulebook

Ladies and Gentlemen:

Pursuant to Commodity Futures Trading Commission (the “Commission”) Regulation 40.6(a), 

Thomson Reuters (SEF) LLC (“TR SEF”) hereby self-certifies the amendments to its Rulebook 

identified in Exhibit A. The Rulebook has been amended in order to update a reference to a 

Commission no-action letter and provide information about the FX Global Code, consistent with 

information that Thomson Reuters, the ultimate parent of TR SEF, also is providing to market 

participants on its other FX trading platforms. The amended Rulebook will become effective on 

August [ ], 2018.

A concise explanation and analysis of the amendments to the Rulebook and their compliance 

with applicable provisions of the Commodity Exchange Act (the “CEA”) is attached hereto as 

Exhibit A, and the amendments showing changes against the version submitted to the 

Commission in Submission 18-01 on May 23, 2018, is attached hereto as Exhibit B.

TR SEF hereby certifies that: (i) the amended Rulebook complies with the CEA and the 

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

concurrently posted on TR SEF’s website. No substantive opposing views were expressed with 

respect to the amendments to the Rulebook.

Please contact me using the information below if you have any questions regarding these 

amendments to the Rulebook.

Wayne Pestone

1333 H Street, NW

Suite 500

Washington, DC 20005 

Phone: (202) 377-7975

Email: wayne.pestone@thomsonreuters.com
2

Sincerely,

Wayne Pestone

Chief Compliance Officer

cc: Nancy Markowitz, Deputy Director, Division of Market Oversight, Exchange and Data 

Repository Branch

Jasmine Lee, Special Counsel, Division of Market Oversight

(Commodity Futures Trading Commission)
A-1

EXHIBIT A

Explanation and Analysis of Material Amendments

Summary: The Rulebook has been amended in order to provide information about the FX 

Global Code and update a reference to a CFTC no-action letter. The amendments showing 

changes against the version submitted to the Commission in Submission 18-01 on May 23, 2018, 

is attached hereto as Exhibit B.

Capitalized terms used but not otherwise defined herein have the meanings assigned to them in 

the Rulebook.

Amendment and Explanation Relevant Law, Regulation or 

Guidance

Legal Information / Disclaimers

Adding information about the FX Global Code and stating 

that: (1) Thomson Reuters (i.e., TR SEF’s ultimate parent) has 

signed a Statement of Commitment to the FX Global Code;

(2) TR SEF supports though does not mandate that its 

Participants sign such a Statement of Commitment; and (3) 

nothing in the FX Global Code supersedes any provision(s) of 

the SEF Rules, CFTC Regulations or the Commodity 

Exchange Act (in each case, as defined in the Rulebook).

Core Principle 2

Rule 402(a)(5)

Revised to refer to CFTC No-Action Letter 17-17 (extending 

no-action relief regarding SEF confirmation and reporting 

related requirements).

CFTC Regulation 37.6(b);

Core Principle 10
B-1

EXHIBIT B

Rulebook Amendments