AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

September 8, 2023

Submitted via Portal

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: 

CFTC Regulation 40.6(a) Required Certification AEGIS SEF, LLC

Amendment to Rulebook

Dear Sir:

Pursuant to Section 40.6(a) of the regulations of the U.S. Commodity Futures Trading 

Commission (the “CFTC”, or the “Commission”), AEGIS SEF, LLC (“AEGIS”) hereby notifies 

the Commission that it has amended its Rulebook. The Rule Amendments shall become effective 

10 days after this submission has been filed or immediately upon approval by the CFTC, 

whichever occurs first.

A concise explanation and analysis of the rules and their compliance with applicable provisions 

of the Act, including core principles and the Commission’s regulations, is attached hereto as 

Exhibit A. A copy of the Rulebook is attached under separate cover as Exhibit B. A redlined 

version of the Rulebook is attached under separate cover as Exhibit C. A copy of AEGIS SEF 

Exhibit N-3 is attached under separate cover as Exhibit D. A redlined version of AEGIS SEF 

Exhibit N-3 is attached under separate cover as Exhibit E. Exhibits D and E bear the designation 

“Confidential Treatment Requested by AEGIS SEF, LLC.”

AEGIS hereby certifies that: (i) the amended rules comply with the Act and the

Commission’s regulations thereunder, and (ii) copy of this submission is being

concurrently posted on AEGIS’s website. There were no substantive opposing views to the

amendments to the Rulebook.

Please contact the undersigned at 832-413-5973 or afurman@aegis-hedging.com with any 

questions regarding this matter.

Andrew Furman

Chief Compliance Officer

AEGIS SEF, LLC
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

2829 Technology Forest Blvd

Suite 260

The Woodlands, TX 77381

Exhibit A – Explanation 

Amendment and Explanation Supporting Rule / Core Principle

Rulebook 3.15.2(g): Broker Firms

• Requires Broker Firm to verify mutual 

credit risk mitigation agreement is in 

place between a Customer and its 

Financial counterparty(s) and verify 

correct Legal Entity Identifier

• Core Principle 2 – Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• Core Principle 5(A)- Obtain 

Information

• Core Principle 10 – Recordkeeping

• Rule 4.6.5(iii)

• Rule 4.10.2

• §37.1000(a)

Exhibit N-3: Offline Execution 

Functionality (OEF)

Supplemented language to include the 

OEF and any additional transaction 

functionality 

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Rulebook Title, Preamble, 1.4, 9.8 • Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Exhibit B – AEGIS SEF Rulebook

(attached under separate cover)

Exhibit C – AEGIS SEF Rulebook (redlined)

(attached under separate cover)

Exhibit D – AEGIS SEF Exhibit N-3

(attached under separate cover, Confidentiality requested)

Exhibit E – AEGIS SEF Exhibit N-3 (redlined)

(attached under separate cover, Confidentiality requested)

(excerpts below)
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381