Scot J. Halvorsen

 TRADITION SEF, Inc. Senior Regulatory Counsel and Secretary

 Legal Department

Tradition SEF, Inc. 255 Greenwich Street, 4th floor, New York, NY 10007 F 212 791 4500 www.traditionsef.com

May 31, 2018

VIA ELECTRONIC PORTAL

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 StreamGlobal Credit Default Swap Trading 

Platform Supplement. 

Tradition SEF Submission No. 2018-03.

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 

StreamGlobal Credit Default Swap Trading Platform Supplement to the Tradition SEF Rulebook 

(the “Platform Supplement”), to be effective and implemented by Tradition SEF as of June 15, 

2018. Attached as Exhibit B is a redlined version of the Platform Supplement reflecting the 

amendments described herein. 

We have identified on Exhibit A amendments to Rule S3-409(e) of the Platform Supplement and 

compliance with the SEF core principles (the “Core Principles”) as set forth in Section 5h 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. 
2

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. 2018-03 in any related correspondence.

Sincerely,

/s/ Scot J. Halvorsen

Senior Regulatory Counsel and Secretary

Attachments: Exhibit A – Compliance with Core Principles table

Exhibit B – Platform Supplement (redline format)
3

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.

Platform 

Supplement

Rule S3-

409(e)

Tradition SEF amended Platform 

Supplement Rule S3-409(e) to facilitate 

Tradition SEF’s CDX Swaps trading 

platform being more readily adapt to 

changing market conditions.

The purpose of this Rule amendment is to 

provide Tradition SEF to readily change the 

Default/Minimum sizes for CDX swaps to 

reflect changing market conditions. 

Default/Minimum Sizes for CDX Swaps for 

the StreamGlobal Platform will be set by 

Tradition SEF from time to time and notice 

of any changes will be provided to 

Participants and Customers prior to the 

effectiveness of any such changes. 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.” 
4

EXHIBIT B

Redlined StreamGlobal Credit Default Swap Trading Platform Supplement

THIS PAGE INTENTIONALLY LEFT BLANK