Scot J. Halvorsen

 Tradition SEF, Inc. General Counsel and Secretary

 Legal Department

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

March 18, 2019

VIA ELECTRONIC PORTAL

Commodity Futures Trading Commission

CFTC FOIA Compliance Office

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Tradition SEF, Inc. FOIA Confidential Treatment Request.

CFTC Regulation 40.6(a) Rule Certification.

Tradition SEF Submission No. 2019-01.

Dear Secretary:

By electronic portal today, March 18, 2019, Tradition SEF, Inc. (the “Submitter”), pursuant to Part 40 of 

the Commodity Futures Trading Commission’s (the “Commission”) regulations, voluntarily provided its 

Trad-X Interest Rate Swap (IRS) trading platform supplement (the “Platform Supplement”) attached to 

Submission No. 2019-01 as Exhibit B (the “Confidential Information”) to the Secretary of the

Commission and staff of the Division of Market Oversight in connection with a Swap Execution Facility 

(“SEF”) rule submission made pursuant to Commission Rule 40.6(a). 

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

Confidential Information contained on the Platform Supplement attached to Submission No. 2019-01 as 

Exhibit B on the grounds that disclosure of such Confidential Information would reveal confidential 

commercial information of the Submitter. The provisions of the Platform Supplement that confidential 

treatment is requested are clearly highlighted in yellow on Exhibit B. The redacted version of the 

Platform Supplement will be publicly available on Tradition SEF’s website. The provisions for which 

confidential treatment is requested describe the Trad-X Credit Matrix functionality, Spread Over Stack 

priority rule characteristics, USD Interest Rate Swaps order sizes, minimum order size applied to USD 

Spread Over orders, and GBP Interest Rate Swaps order sizes. Such information is proprietary to 

Submitter’s platform and represents commercial methodologies that provide value and differentiate the 

Submitter from its competitors.

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 submission, please contact the undersigned at 

(212) 377-2337 or scot.halvorsen@tradition.com. Please reference Tradition SEF Submission No. 2019-

01 in any related correspondence.

Sincerely,

/s/ Scot J. Halvorsen

General Counsel and Secretary