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

June 18, 2018

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. 2018-04.

Dear Secretary:

By electronic portal today, June 18, 2018, 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. 2018-04 as Exhibit A (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. 2018-04 as Exhibit A 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 A. 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 minimum order size applied to USD Spread Over Orders placed on the Trad-X 

Platform. Such Order size 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. 2018-04 in any related correspondence.

Sincerely,

/s/ Scot J. Halvorsen

Senior Regulatory Counsel and Secretary