RTX Fintech & Research LLC

128 East 31st Street, 2nd Floor

New York, NY 10016

1

April 27, 2022

By Email

Secretary of the Commission

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

secretary@cftc.gov

Re: Updated Request for Full Registration as a Swap Execution Facility

Dear Secretary Kirkpatrick:

On March 16, 2022, RTX Fintech & Research LLC (“RTX SEF”) submitted a Swap Execution Facility (“SEF”) 

application in accordance with Section 5h of the Commodity Exchange Act and Part 37 of the regulations

promulgated by the Commodity Futures Trading Commission (“CFTC” or “Commission”).

Since then, CFTC staff have asked that RTX SEF amend certain items in its application. RTX SEF submitted 

a first amendment to its SEF application on March 25, 2022 that addressed part of the CFTC 

staff’s request. RTX SEF addressed the remainder of the CFTC staff’s request in a second amendment, 

which it submitted on April 21, 2022.

Yesterday CFTC staff has asked that RTX SEF update its transmittal letter with the current set of 

confidential exhibits. To satisfy this request, RTX SEF hereby submits this updated request for full 

registration as a SEF.

RTX SEF respectfully requests that the CFTC grant RTX SEF’s application for full registration pursuant to 

Commission regulation 37.3(b). Pursuant to Commission regulation 37.3(b)(1)(iii), RTX SEF requests from 

the Commission a unique, extensible, alphanumeric code for the purpose of identifying the SEF pursuant 

to Part 45 of the Commission’s regulations.

RTX SEF has submitted to the Assistant Secretary of the Commission for Freedom of Information a 

request for confidential treatment of the documents listed on Appendix A hereto (the “Confidential 

Information”). RTX SEF has provided a copy of the request for your information. The basis for this 

petition for confidential treatment is CFTC Regulation Section 145.9(d)(1)(ii), in that the Confidential 

Information contains trade secrets and confidential commercial and/or financial information. RTX SEF

requests this confidential treatment for an indefinite period.
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If you have any questions regarding this application, please contact RTX SEF’s Chief Compliance Officer 

Patrick McCarty at (201) 577-4702.

Sincerely, 

David Nelson

Vice President

Cc by email:

Division of Market Oversight, Commodity Futures 

 Trading Commission (dmosubmissions@cftc.gov)

Nancy Markowitz, Division of Market Oversight, Commodity Futures

 Trading Commission (nmarkowitz@cftc.gov)

Jonathan Lave, Division of Market Oversight, Commodity Futures 

 Trading Commission (Jlave@cftc.gov)

Matt Jones, Division of Market Oversight, Commodity Futures 

 Trading Commission (Majones@cftc.gov)
1

Confidential Information

Name of 

Confidential 

Information

Description Identifying Number 

and Code

A List of control persons of RTX Fintech & Research LLC (“RTX SEF”) RTX SEF Exhibit A

B List of officers and directors of RTX SEF RTX SEF Exhibit B

D RTX SEF organizational chart, addresses for legal service of process RTX SEF Exhibit D

E Qualifications of RTX SEF’s professional employees RTX SEF Exhibit E

F Staffing requirements of RTX SEF; name and qualifications of each 

key staff person

RTX SEF Exhibit F

H List of material pending legal proceedings RTX SEF Exhibit H

I Statement of financial condition of RTX SEF, operating costs, 

financial resources, and sources of operational resources of RTX SEF

RTX SEF Exhibit I

J Financial information of certain RTX SEF affiliates RTX SEF Exhibit J

K RTX SEF fee schedule RTX SEF Exhibit K

N Service agreements RTX SEF Exhibit N

N-1 Exhibit N-1 RTX SEF Exhibit N, N-1

N-2 Exhibit N-2 RTX SEF Exhibit N, N-2

N-3 Exhibit N-3 RTX SEF Exhibit N, N-3

N-4 Exhibit N-4 RTX SEF Exhibit N, N-4

N-5 Exhibit N-5 RTX SEF Exhibit N, N-5

N-6 Exhibit N-6 RTX SEF Exhibit N, N-6

N-7 Exhibit N-7 RTX SEF Exhibit N, N-7

N-8 Exhibit N-8 RTX SEF Exhibit N, N-8

N-9 Exhibit N-9 RTX SEF Exhibit N, N-9

N-10 Exhibit N-10 RTX SEF Exhibit N, N-10

N-11 Exhibit N-11 RTX SEF Exhibit N, N-11

N-12 Exhibit N-12 RTX SEF Exhibit N, N-12

N-13 Exhibit N-13 RTX SEF Exhibit N, N-13

N-14 Exhibit N-14 RTX SEF Exhibit N, N-14

O RTX SEF compliance manual RTX SEF Exhibit O

P RTX SEF disciplinary and enforcement procedures; alternative 

dispute resolution

RTX SEF Exhibit P

Q Explanation of RTX SEF’s trading systems and platforms RTX SEF Exhibit Q

S Discussion of how RTX SEF’s trading data will be maintained RTX SEF Exhibit S

V RTX SEF’s responses to the technology questionnaire RTX SEF Exhibit V

Appendix Appendix to Exhibit V with technology risk documentation RTX SEF Exhibit V, 

Appendix

V RTX SEF’s amended responses to the technology questionnaire RTX SEF Exhibit V

Appendix Amended Appendix to Exhibit V with responsive technology risk 

documentation

RTX SEF Exhibit V, 

Appendix