Thomson Reuters (SEF) LLC

3 Times Square

New York, NY 10036

February 24, 2016

Submitted Via Portal

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: Submission 16-01A: Thomson Reuters (SEF) LLC – Amendments to Rulebook

Ladies and Gentlemen:

Pursuant to Commodity Futures Trading Commission (the “Commission”) Regulation 40.6(a), 

Thomson Reuters (SEF) LLC (“TR SEF”) hereby self-certifies the amendments to its Rulebook, 

including certain changes made in its previous Submission 16-01, which are collectively 

identified in Exhibit A. TR SEF is submitting these amendments in response to comments and 

questions received from TR SEF Participants and Commission Staff. The amended Rulebook 

will become effective on March 9, 2016.

A concise explanation and analysis of the amendments to the Rulebook and their compliance 

with applicable provisions of the Commodity Exchange Act (the “CEA”) is attached hereto as 

Exhibit A, and the amendments showing changes against the Rulebook version submitted to the 

Commission in Submission 15-05 on December 22, 2015, is attached hereto as Exhibit B.

TR SEF hereby certifies that: (i) the amended Rulebook complies with the CEA and the 

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

concurrently posted on TR SEF’s website. No substantive opposing views were expressed with 

respect to the amendments to the Rulebook.

Please contact me using the information below if you have any questions regarding these 

amendments to the Rulebook.

Wayne Pestone

1100 13th Street, NW

Suite 200

Washington, DC 20005 

Phone: (202) 572-0198

Email: wayne.pestone@thomsonreuters.com
2

Sincerely,

Wayne Pestone

Chief Compliance Officer

cc: Nancy Markowitz, Deputy Director, Division of Market Oversight, Exchange and Data 

Repository Branch
A-1

EXHIBIT A

Explanation and Analysis of Material Amendments

Summary: The Rulebook has been amended in response to comments and questions received 

from TR SEF participants. The amendments showing changes against the version submitted to 

the Commission in Submission 15-05 on December 22, 2015, is attached hereto as Exhibit B.

Capitalized terms used but not otherwise defined herein have the meanings assigned to them in 

the Rulebook.

Amendment and Explanation Relevant Law, Regulation or 

Guidance

Introductory Notice

Added reference to Sponsored Persons so that such Persons 

agree: (1) to be bound by, and comply with, the SEF Rules 

and obligations and Applicable Law, in each case to the extent 

applicable to it; (2) to become subject to the jurisdiction of the 

SEF with respect to any and all matters arising from, related 

to, or in connection with, the status, actions or omissions of 

such Person; (3) to permit the SEF and any Regulatory 

Services Provider authorized to act on behalf of the SEF to 

access any and all information relevant to activities related to 

the SEF business; (4) to assist the SEF in complying with its 

legal and regulatory obligations, cooperate with the SEF and 

the CFTC in any inquiry, investigation, audit, examination or 

proceeding; and (5) that the SEF is authorized to provide 

information regarding such Person to the Regulatory Services 

Provider, the CFTC or any Self-Regulatory Organization.

Core Principles 2, 4 and 5

Table of Contents

Updated Table of Contents.

Conforming change

Chapter 1

Amended definition of “Intermediary Agreement” by adding 

reference to Sponsored Persons.

Core Principle 2

Chapter 1

Amended definition of “SEF Activity” to include business for 

which a Sponsored Person is subject to the SEF Rules or 

which is purportedly conducted subject to the SEF Rules.

Core Principle 2
A-2

Amendment and Explanation Relevant Law, Regulation or 

Guidance

Chapter 1

Added definition of “Sponsored Access” to mean the process 

by which a Participant (“Sponsoring Participant”) provides 

Trading Privileges on the SEF to a market participant who is 

not a Participant (“Sponsored Person”). Sponsored Access 

takes multiple forms, including but not limited to: (a) 

“Sponsored Market Access”, where the Sponsoring 

Participant provides the connection to the SEF and the 

Sponsored Person’s orders pass through the Sponsoring 

Participant’s systems prior to reaching the Platform, and (b) 

“Direct Access”, where the Sponsored Person enters orders 

directly into the Platform via its own dedicated connection 

provided by the SEF under the auspices of and via an 

arrangement with the Sponsoring Participant, pursuant to Rule 

316.

Core Principle 2

Chapter 1

Added definition of “Sponsored Person” to mean an Eligible 

Contract Participant which has been provided electronic 

access to and Trading Privileges on the SEF by means of a 

Sponsoring Participant pursuant to Rule 316, and who shall be 

subject to the jurisdiction of the SEF and comply with the 

SEF Rules as if such Sponsored Person was a Participant. For 

the avoidance of doubt, all references to Participant other than 

in Rules 302(a), 305 and 314 shall include Sponsored Persons 

and their Authorized Persons.

Core Principle 2

Chapter 1

Added definition of “Sponsoring Participant” to mean a 

Participant that has (i) designated a Sponsored Person to the 

SEF pursuant to the SEF Rules and (ii) extended Trading 

Privileges to such Sponsored Person. Upon acceptance of 

such designation by the SEF, the Sponsoring Participant shall 

be responsible for the obligations provided in Rule 316.

Core Principle 2

Rule 301(b)

Amended rule to require Sponsoring Participants to enter into 

an Intermediary Agreement with Sponsored Persons.

Core Principles 2 and 4
A-3

Amendment and Explanation Relevant Law, Regulation or 

Guidance

Rule 303(c)

Revised to clarify that Sponsored Persons are deemed to have 

been granted Trading Privileges on the SEF.

Core Principle 2

Rule 304(a)

Revised to specify the conditions under which TR SEF may 

revoke, suspend, limit, condition, restrict or qualify a

Sponsored Person’s Trading Privileges.

Core Principle 2

Rule 307(a)

(1) Revised to specify that Sponsored Persons shall be 

identified by their Legal Entity Identifiers.

(2) Removed reference to using CICIs in the event that the 

CFTC has not yet designated the procedures for obtaining a 

Legal Entity Identifier. 

(1) Core Principles 2, 4 and 5

(2) Conforming change

Rule 309(b)

Revised to specify that a Notice to Participants published and 

transmitted in accordance with Rule 309(a) shall also be 

deemed to have been made to all Sponsored Persons.

Core Principle 2

Rule 311(a)

Added reference to Sponsored Persons so that such Persons 

agree (1) to be bound by, and comply with, the SEF Rules and 

obligations and Applicable Law, in each case to the extent 

applicable to it; (2) to become subject to the jurisdiction of the 

SEF with respect to any and all matters arising from, related 

to, or in connection with, the status, actions or omissions of 

such Person; (3) to permit the SEF and any Regulatory 

Services Provider authorized to act on behalf of the SEF to 

access any and all information relevant to activities related to 

the SEF business; (4) to assist the SEF in complying with its 

legal and regulatory obligations, cooperate with the SEF and 

the CFTC in any inquiry, investigation, audit, examination or 

proceeding; and (5) that the SEF is authorized to provide 

information regarding such Person to the Regulatory Services 

Provider, the CFTC or any Self-Regulatory Organization.

Core Principles 2, 4 and 5
A-4

Amendment and Explanation Relevant Law, Regulation or 

Guidance

Rule 315(a)

Revised to require that all Sponsored Persons comply with the 

provisions of the CEA and CFTC Regulations.

Core Principle 2

Rule 316

Added new rule specifying certain requirements for 

Sponsored Persons and Sponsoring Participants in connection 

with Sponsored Access.

Core Principles 2, 4 and 5

Rule 501(a)

Revised to specify certain duties applicable to Sponsored 

Persons.

Core Principle 2

Rule 503(c)

Revised to specify that the Market Regulation Department 

may examine (periodically or on a particular occasion) the 

books and records of any Sponsored Person that relate to SEF 

Activity.

Core Principles 2 and 5

Rule 505(c)

Revised to specify that, as required by CFTC Regulations §§ 

1.31 and 37.404, each Sponsored Person must keep records of 

its trading on the SEF, including records of its activity in the 

commodity underlying any Swap and trading on related 

derivatives markets and make such records available, upon 

request, to the SEF, the CFTC, and the Department of Justice.

Core Principles 2 and 5

Rule 915

Revised to specify that Sponsored Persons are not required to 

have a User Agreement.

Core Principle 2

Rule 929(b)

Revised to specify the circumstances under which the SEF 

may modify or adjust trade prices, or cancel Transactions, 

submitted by Sponsored Persons.

Core Principles 2, 7 and 8
A-5

Amendment and Explanation Relevant Law, Regulation or 

Guidance

Rule 1001(a)

Revised to include Sponsored Persons within the defined term 

“SEF Market Participants.”

Core Principles 2 and 5

Rule 1101(c)(1)

Revised to specify that claims of a Sponsored Person that is 

not itself a Participant against a Participant that relate to or 

arise out of any Transaction on or subject to the SEF Rules

may be submitted for arbitration through the National Futures 

Association Arbitration Program.

Core Principle 2
B-1

EXHIBIT B

Rulebook Amendments