Daniel E. Glatter

General Counsel and Secretary

 TRADITION SEF, Inc. 

Tradition SEF, Inc. 32 Old Slip, 28th Floor, New York, NY 10005 F 212 791 4500 www.traditionsef.com

August 10, 2020

VIA CFTC Portal

Mr. Christopher Kirkpatrick

Secretary

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: CFTC Regulation 40.6(a) Certification.

Notification of Amendments to Tradition SEF, Inc. Rulebook

Tradition SEF Submission No. 2020-04

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 of modifications to the Trad-X USD IRS Liquidity 

Provider Program (“LPP”), as described below, to be effective for market participants on August 24, 

2020. 

Pursuant to Tradition SEF Inc. Rule 536, Tradition SEF has modified certain terms of the Trad-X USD 

IRS Liquidity Provider Program as previously noticed in Notice to Participants 19-04. A petition for 

confidential treatment will accompany this request and be filed with the Secretary’s office.

We have identified in Exhibit A the rule modifications and 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. A redline version of the Rulebook is attached hereto 

as Exhibit B to reflect the changes to the last version of the Rulebook. 

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 rule amendments 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 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. 

Should you require additional information related to this submission, please contact the undersigned at 

(212) 377-2337 or daniel.glatter@tradition.com. Please reference Tradition SEF Submission No. 2020-

04 in any related correspondence.

Sincerely,

/s/ Daniel E. Glatter

General Counsel and Secretary

Att.:

Exhibit A

Exhibit B
EXHIBIT A

Amendments to the Rulebook

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 20-

05

Modifications to the Trad-X USD IRS Liquidity Provider 

Program (“LPP”).

The modifications to the Trad-X USD 

IRS LPP demonstrate Tradition 

SEF’s adherence to open access 

principles. Accordingly, Tradition is 

promoting a fair, transparent 

platform. The modifications comply

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

Participant Notice 20-05

THIS PAGE INTENTIONALLY LEFT BLANK 

EXHIBIT B IS SUBJECT TO A REQUEST FOR CONFIDENTIAL TREATMENT