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

July 26, 2022

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(d) Notification. AEGIS SEF, LLC Weekly 

Notification of Rule Amendments

Dear Sir:

Pursuant to Section 40.6(d) 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 Exhibits N-1, Exhibit N-3, and Exhibit K. The amended 

Exhibits N-1, Exhibit N-3, and Exhibit K became effective on July 20, 2022.

A concise explanation and analysis of the amendments to the Exhibits N-1, Exhibit N-3, and 

Exhibit K and their compliance with applicable provisions of the Act, including core principles 

and the Commission’s regulations, is attached hereto as Exhibit A. Clean copies of the amended 

Exhibit N-1, Exhibit N-3, and Exhibit K are attached under separate cover as Exhibit B, C and D, 

respectively. Copies of the amended Exhibit N-1, N-3, and K marked to show changes against 

previous version are attached under separate cover as Exhibit E, F and G respectively.

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

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

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

amendments to Exhibit N-1, Exhibit N-3, and Exhibit K.

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

2829 Technology Forest Blvd

Suite 260

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

Exhibit A – Explanation 

Amendment and Explanation Supporting Rule of Core Principle

Ex. N-1 Participant Agreement

• Optimized formatting (p.1)

• The change to 5.a. Term of the 

Participant Agreement references the 

Effective Date to remove any 

ambiguity (p.7)

• The change to 5.b. Termination for 

Breach of the Participant Agreement 

removes the word “immediately” to 

provide a Participant with adequate 

opportunity to redress a payment

deficiency. (p.7)

• Optimized formatting (p.11)

• Updated address and email

• Conforming changes to attachment B. 

(see below “Ex. K Fee Schedule”)

• 40.6(d)(2)(i)

• 40.6(d)(2)(i)

• 40.6(d)(2)(i)

• 40.6(d)(2)(i)

• 40.6(d)(2)(i)

• See below

Ex. N-3 Market Participant Addendum

• Optimized formatting (p.1)

• Inserted the word “prevailing” to 

clarify reference to existing document 

(p.1)

• Optimized formatting (p.3)

• Added “Date” field

• 40.6(d)(2)(i)

• 40.6(d)(2)(i)

• 40.6(d)(2)(i)

• 40.6(d)(2)(i)

Ex. K Fee Schedule

• Monthly user access fees to 

commence 11/1/2022. Change in fees 

is a one-time startup adjustment –

impartial to all Participants. Fees are 

unrelated to trading. (p.2)

• Payment was changed to 30 days (p.3)

• 40.6(d)(2)(v)(B)

• 40.6(d)(2)(i)
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Exhibit B – Participant Agreement, Exhibit N-1 (clean)

(attached under separate cover)

Exhibit C – Market Participant Addendum, Exhibit N-3 (clean)

(attached under separate cover)

Exhibit D – Fee Schedule, Exhibit K (clean)

(attached under separate cover)

Exhibit E – Participant Agreement, Exhibit N-1 (redline)

(attached under separate cover)

Exhibit F – Market Participant Addendum, Exhibit N-3 (redline)

(attached under separate cover)

Exhibit G – Fee Schedule, Exhibit K (redline)

(attached under separate cover)