Daniel E. Glatter

General Counsel and Secretary

TRADITION SEF, Inc. 

Tradition SEF, Inc. 32 Old Slip, 28th Floor, New York, NY 10005 F 212 791 4500 www.traditionsef.com

June 12, 2020

VIA CFTC PORTAL

Assistant Secretary of the Commission for FOIA,

Privacy and Sunshine Acts Compliance

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Tradition SEF, Inc. – FOIA Confidential Treatment Request

Dear Sir or Madam:

By CFTC Portal submission today, April 7, 2020, Tradition SEF, Inc. (the “Submitter”) provided the 

information attached as Exhibit A (the “Confidential Information”) and attached hereto to the Commodity 

Futures Trading Commission (the “Commission”) and staff of the Division of Market Oversightregarding 

modifications to the Tradition SEF Trad-X USD IRS Liquidity Provider Program. .

Pursuant to Commission Rules 40.8 and 145.9(d), the Submitter requests confidential treatment of the 

Confidential Information consisting of Exhibit A to this submission on the grounds that disclosure of the 

Confidential Information would reveal confidential commercial and financial information of the 

Submitter and its employees and would be considered commercially material information to competitors 

of the Submitter. 

Submitter’s notice that is reflected on Exhibit A contains information that is proprietary to the Submitter 

and forms an integral part of the competitive nature of the marketplace. Hence pending completion of its 

review and for the Submitter to continue to operate its business without undue inquiry, distraction or 

interruption, it is imperative that such information be treated as confidential. Accordingly, the Submitter 

requests confidential treatment of Exhibit A in its entirety.

Pursuant to Commission Rule 145.9(d)(5), the Submitter requests that confidential treatment of the 

Confidential Information be maintained until further notice from the Submitter. The Submitter requests 

that the Commission notify it immediately after receiving any request under the Freedom of Information 

Act (“FOIA”) or any other court order, subpoena or summons for the Confidential Information. The 

Submitter specifically notes that it does not waive, in any manner, its rights under Section 8(f) of the 

Commodity Exchange Act to receive a copy of any subpoena or summons for the Confidential 

Information prior to the Commission’s disclosure of such information pursuant to such subpoena or 

summons. Finally, the Submitter requests that the Commission notify it in the event that the Commission 

intends to disclose the Confidential Information to Congress or any federal or state governmental agency 

or department.

Should you require additional information related to this request, please contact the undersigned at (212) 

377-2337 or daniel.glatter@tradition.com.
Assistant Secretary of the Commission for FOIA, 

Privacy and Sunshine Acts Compliance

June 12, 2020

Page 2

Sincerely,

/s/ Daniel E. Glatter

General Counsel and Secretary

Att.
Assistant Secretary of the Commission for FOIA, 

Privacy and Sunshine Acts Compliance

June 12, 2020

Page 3

EXHIBIT A

Confidential Information

▪ Three page document titled “Tradition SEF Participant Notice 20-03 - Modifications to Tradition SEF -

Trad-X USD IRS Liquidity Provider Program (“LPP”)”
CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

Tradition SEF, Inc.

Participant Notice 20-03

Modifications to Tradition SEF - Trad-X USD IRS Liquidity Provider Program (“LPP”)

June 12, 2020

To : Tradition SEF Authorized Representatives

From : Tradition SEF Legal, Compliance, and Operations

_______________________________________________________________________________

Authorized Representatives,

Pursuant to Tradition SEF Rule 536, and Tradition SEF Notice to Participants 19-04, Tradition SEF

hereby provides notice of modifications to certain terms of the Trad-X USD IRS Liquidity Provider 

Program, (the “LPP”). The effective date for the modifications to the LPP is July 1, 2020.

The objective of the LPP is to incentivise Electronic Liquidity Providers (“ELPs”) to stream twosided liquidity to the Trad-X USD electronic order book. The incentive comes in the form of fee 

discounts applied to ELP’s SEF USD IRS voice transactions.

Please note that the LPP is considered confidential and is intended only for Tradition SEF Participants 

and Customers, and is not to be disseminated outside of a Participant’s or Customer’s organization.

Furthermore, a request for confidential treatment has been submitted to the CFTC regarding certain 

details of the modifications.

1) Changes / revisions to the LPP: 

The qualifying streaming sizes have been revised. From July 1, 2020, and until further notice, 

qualifying streaming sizes will be as per the chart below: 

QUALIFYING MINIMUM 

SIZES AND EXAMPLE: RAAS 

POINTS TOTAL BASED ON 7 

HOURS OF STREAMING

Qualifying 

Size (MM)

ELP 

bid/offer Weight*

ELP 

RAAS 

Points

W*R

Spread Over

5 Year 50 0.5 1 117 117

10 Year 25 0.5 1 117 117

30 Year 10 0.625 1 290 290

Spread Over Switches

5v10 25 0.5 1 117 117

10v30 10 0.625 1 290 290

TOTAL (1) :

 

931 
CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

Rates Semi Bond vs 3M

1 Year 100 0.5 0.25 117 29.25

2 Year 75 0.5 0.25 117 29.25

5 Year 30 0.5 0.25 117 29.25

10 Year 15 0.5 0.25 117 29.25

30 Year 5 0.625 0.25 290 72.50

Rates Semi Bond vs 3M 

Spread/Flies

5v10 15 0.5 0.25 117 29.25

10v30 5 0.625 0.25 290 72.50

5v7v10 40 0.5 0.25 117 29.25

10v20v30 15 0.5 0.25 233 58.25

TOTAL (2) :

 

379

Qualifying 

Size 

($MM)

ELP 

bid/offer Weight*

ELP 

RAAS 

Points 

W*R

1Year Gap Fly:

2x3x4 100 0.5 0.25 117 29.25

3x4x5 100 0.5 0.25 117 29.25

4x5x6 100 0.5 0.25 117 29.25

5x6x7 100 0.5 0.25 117 29.25

6x7x8 100 0.5 0.25 117 29.25

7x8x9 100 0.5 0.25 117 29.25

8x9x10 100 0.5 0.25 117 29.25

9x10x11 100 0.5 0.25 117 29.25

10x11x12 100 0.5 0.25 177 44.25

TOTAL (3) :

 

278 

Minimum Daily RAAS Score to 

qualify for ELP incentives (Sum 

of Totals 1,2 & 3 )

 

1,200

RAAS is calculated based on the number of hours streamed each day. The above example is based on 

seven hours streaming. ELPs may earn additional RAAS points for streaming additional hours.

Streaming tighter two-way markets will also increase RAAS scores.

2) Additional LPP Incentive: 
CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

In addition to the LPP incentives outlined in Notice 19-04, ELP’s transaction fees will be waived 

for transactions resulting from interaction with an ELP’s passive electronic stream.

Please contact us at the contact information below with any questions. 

.

For Tradition SEF legal matters, please contact:

Dan Glatter, General Counsel: (212) 377 2337 or daniel.glatter@tradition.com

For SEF compliance or administrative questions please contact:

Eric Earnhardt, CCO: (212) 791 3497 or eric.earnhardt@tradition.com

Jeff Mehan, CAO: (212) 943 4567 or jeff.mehan@tradition.com