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Tradition SEF, Inc. Senior Regulatory Counsel and Secretary
Legal Department

August 19, 2016

VIA E-MAIL (FOIASubmissions@cfic.gov)

Assistant Secretary of the Commission for FOIA Matters
Commodity Futures Trading Commission

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) Emergency Rule Certification.
Tradition SEF Submission No. 2016-05.

Dear Secretary:

By e-mail dated today, August 19, 2016, 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
hereto 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 hereto as Exhibit A to this
request on the grounds that disclosure of the Confidential Information would reveal confidential
commercial information of the Submitter. The provisions of the Platform Supplement that confidential
treatment is requested are clearly marked as “Redacted — Confidential Treatment Requested” on Exhibit
A and the applicable text is stricken. 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 Submitter’s credit (Risk Limit) allocation methods, credit (Risk Limit) management and
default trading size terms on the platform to perform pre-trade credit checks for cleared IRS trades and
USD interest rate products minimum order sizes. These processes and order sizes are proprietary to
Submitter’s platform and represent commercial methodologies that provide value and differentiate the
Submitter from its competitors. Credit (Risk Limit) allocation on a SEF is a function of the interaction
between the SEF platform and the systems of Futures Commission Merchants (FCMs) that clear trades on
a SEF platform on behalf of participants and customers through a Designated Clearing Organization
(DCO). When a SEF provides an efficient credit (Risk Limit) mechanism to FCMs for credit
management purposes, it increases the probability that such FCM will make credit available to other SEF
participants. As such, it increases the SEF’s volume and client base.

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

Tradition SEF, Inc. 255 Greenwich Street, 4"" floor, New York, NY 10007 F 2127914500 www.traditionsef.com


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. 2016-
05 in any related correspondence.

Sincerely,

‘scot J. HalVorsen

Senior Regulatory Counsel


Exhibit A
Confidential Information
Tradition SEF Trad-X Interest Rate Swap (IRS) Trading Platform Supplement (identifying
redactions)

Tradition SEF Trad-X Interest Rate Swap (IRS) Trading Platform Supplement (publicly available
redacted version)