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

August 2, 2019

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 Tradition SEF, Inc. Liquidity Provider Program. 

Tradition SEF Submission No. 2019-03. 

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, Tradition SEF, Inc. 

(“Tradition SEF”) hereby notifies the Commission that Pursuant to Tradition SEF Rule 536, Tradition 

SEF hereby provides notice of the implementation of a Trad-X USD IRS Liquidity Provider Program,

(the “LPP”), as set forth in the LPP Program description contained on Participant Notice 19-04 attached 

hereto as Exhibit B. The effective date for the commencement of the LPP is August 16, 2019. 

We have identified on Exhibit A the LPP’s compliance with the SEF core principles (“Core Principles”) 

as set forth in Section 5h of the Commodity Exchange Act and Part 37 of the Commission’s regulations 

promulgated thereunder. Tradition SEF has simultaneously submitted a request for confidential treatment 

for Exhibit B (Participant Notice 19-04). 

Tradition SEF continues to be in compliance with applicable provisions of the Act, including the Core 

Principles. In particular, Tradition SEF has determined that it is in compliance with Core Principles 1 

(Compliance with Core Principles) and 2 (Compliance with Rules), as further described in the compliance 

chart attached as Exhibit A. 

Tradition SEF hereby certifies that the LPP’s terms comply with the Commodity Exchange Act and the 

Commission’s regulations promulgated thereunder. No substantive opposing views were expressed that 

were not incorporated into the LPP. Tradition SEF hereby certifies that it has posted a notice of pending 

certification with the Commission and a redacted version of the submission on its website (see

http://www.traditionsef.com/regulatory/), concurrent with the filing of this submission with the 

Commission. 
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-

03 in any related correspondence.

Sincerely,

/s/ Scot J. Halvorsen

General Counsel and Secretary

Exhibit A

Exhibit B (Confidential treatment requested)
EXHIBIT A

Liquidity Provider Program

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.

Participant 

Notice 19-04

Implementation of a Trad-X USD IRS Liquidity Provider 

Program (the “LPP”). 

The Implementation of a Trad-X USD 

IRS LPP demonstrates Tradition 

SEF’s adherence to open access 

principles. Accordingly, Tradition is 

promoting a fair, transparent platform. 

The LPP complies with Core 

Principle 2 (Compliance with Rules) 

and specifically with CFTC Rule 

37.202, which requires impartial 

access to the SEF and transparent 

criteria governing access that is 

applied in a fair and 

nondiscriminatory manner. CFTC 

Rule 37.202 also requires a SEF to 

require that an eligible contract 

participant (“ECP”) consent to its 

jurisdiction before the ECP can access 

the SEF. By complying with Core 

Principle 2, Tradition SEF 

demonstrates its compliance with 

Core Principle 1 (Compliance with 

Core Principles) and CFTC 

Regulation 37.100, which requires 

that a SEF comply with any 

requirement that the CFTC may 

impose by rule or regulation. 
EXHIBIT B

Liquidity Provider Program Description

Participant Notice 19-04

THIS PAGE INTENTIONALLY LEFT BLANK

EXHIBIT B IS SUBJECT TO A REQUEST FOR CONFIDENTIAL TREATMENT