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

October 7, 2019 

VIA E-MAIL (submissions@cftc.gov) 

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. Fee Schedule. 

Tradition SEF Submission No. 2019-04 

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 amendments to its Fee Schedule, as described 

below, to be effective for market participants on October 21st, 2019. 

Tradition SEF has amended Section E (Transaction Fees) of its Fee Schedule to reflect a revised fee in the 

Rates service area for IRS (Futures Unchanged) transactions. 

We have identified in Exhibit A the modified fees 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 redlined fee schedule is attached hereto as Exhibit B to reflect the 

changes to the last version of the fee schedule. Tradition SEF has simultaneously submitted a request for 

confidential treatment for Exhibit B. 

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 fee schedule 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. 2019-

04 in any related correspondence. 

Sincerely, 

/s/ Daniel E. Glatter 

General Counsel and Secretary 

Exhibit A 

Exhibit B (Confidential treatment requested) 

 
EXHIBIT A 

Amendments to Fee Schedule 

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. 

Fee 

Schedule

The fee schedule has been amended to reflect revisions to the 

fees for Futures Unchanged IRS trades. 

The changes to the fee schedule 

demonstrates Tradition SEF’s 

adherence to open access principles. 

Accordingly, Tradition is promoting a 

fair, transparent platform. The 

changes to the fee schedule 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 

Redlined Fee Schedule 

THIS PAGE INTENTIONALLY LEFT BLANK 

EXHIBIT B IS SUBJECT TO A REQUEST FOR CONFIDENTIAL TREATMENT