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

October 14, 2022

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

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. The rule amendment submission from 

AEGIS SEF modifies its authority over Participants with respect to inspections, trade reviews,

position transfers and record requests to be congruent with the transactions taking place on the 

SEF, without in any way diminishing the authority and jurisdiction of the SEF over such matters.

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.

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

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

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

amendments to the rule.

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

questions regarding this matter.

Andrew Furman

Chief Compliance Officer

AEGIS SEF, LLC

2829 Technology Forest Blvd

Suite 260

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

Exhibit A – Explanation 

Amendment and Explanation Supporting Rule / Core Principle

Updating Rule 3.13.1 – Inspections by 

AEGIS-SEF

• Prior inspection language was overly

broad.

• New language focuses inspections on 

systems, equipment, and software 

used specifically in connection with 

SEF activity (versus “relating to”) and 

also narrows the focus specifically to 

Bids/Offers, SEF Contracts, RFQs and 

responses to RFQs (versus “related 

to”).

• Financial Counterparties are 

specifically concerned that “relating 

to” or “related to” could open up 

inspection rights across many 

functions. 

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 5(A)- Ability to obtain 

information

• Core Principle 11(A)(B) – restraint of 

trade, anticompetitive burden

• §1.31(d)(3)

Updating Rule 3.13.4 – Inspections by 

AEGIS-SEF

• Limiting inspection requests to only 

happen upon a failure to produce 

requested records.

• Inspection language narrowed and

allows AEGIS-SEF to initiate 

inspection requests after the subject of 

the investigation has failed to respond

with request.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 5(A)- Ability to obtain 

information

• Core Principle 11(A)(B) – restraint of 

trade, anticompetitive burden

• §1.31(d)(3)
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Updating Rule 3.13.5 – Inspections by 

AEGIS-SEF

• Ensuring any information obtained 

through inspections as Proprietary 

Data.

• There was no prior limitation in the 

handling of records, which is 

challenging for Financial 

Counterparties to agree to. 

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 11(A)(B) – restraint of 

trade, anticompetitive burden.

• §1.31(d)(3)

• AEGIS SEF Rulebook 2.8.4

Updating Rule 3.15.1 – Broker Firms

• Updates the authority of Broker Firms

to assist Participants using both the 

Order Book and the RFQ function.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• § 37.9(c)(2)- Execution Methods

Updating Rule: 4.1.2- Procedures

Addition of the “Broker Firms” and 

“Authorized Users” to be inclusive 

along with Participants for 

notifications and opportunity for 

comment

• §40.6(a)(7) – Rule Submissions

Updated Rule 4.12 – Position Transfers

• Clarifies that the SEF may effect 

transfers of positions on only cleared 

or otherwise non-bilateral positions

AEGIS-SEF only assists with 

permitted bilateral swaps; it does not 

house any positions which can be 

transferred

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• AEGIS SEF Rulebook 4.6.1. 4.18.6 –

SEF Contracts that are not cleared
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Updated Rule 4.13.1 – Trade Cancellation 

Authority

• Clarification was made to show that 

Trade Cancellation Authority only 

applies to the Order Book.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4- Monitoring of 

trading and trade processing

Updated Rule 4.13.2 – Review of Trades 

and Resolution of Errors Among SEF 

Contract Parties; Error Trades

• Review of trades for amendment or 

cancellation for SEF Contracts which 

are illiquid was reduced from 60 

minutes to 10 minutes

• Participants are concerned that too 

lengthy a delay in review can result in 

a greater economic impact 

• AEGIS SEF still maintains the 

authority to review and amend trades 

during the entire business day 

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4- Monitoring of 

trading and trade processing

• §37.9(e)(2)(i) – timely resolution

Updated Rule 4.14.2 – Clearing

• Clarified that Broker Firms (which are 

not Participants) cannot enter cleared 

transactions. 

• Core Principle 2 – Compliance with 

rules

• 4.6.1, 4.7.7, 4.18.6 of the AEGIS SEF 

Rulebook 

Updating Rule 7.2(c)(ii) – Produce Records

• Ensures a narrower request of 

information “specifically” as it 

pertains to investigations.

 

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 11(A)(B) – restraint of 

trade, anticompetitive burden.

• §1.31(d)(3)
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 - Redline

(attached under separate cover)