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

July 7, 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. 2020-03

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 Rulebook Platform Suuplement 

1 for the Trad-XUSD IRS Trading Platform, as described below, to be effective for market participants 

on July 21, 2020. 

Pursuant to Tradition SEF Inc. Rule 536, Tradition SEF has modified certain terms of its Rules as for 

USD IRS Products as contained in Platform Supplement 1 for the Trad-X IRS Trading Platform.

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 Platform Supplement 1 to the 

Rulebook is attached hereto as Exhibit B to reflect the changes to the last version of Platform Supplement 

1 to 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-

03 in any related correspondence.

Sincerely,

/s/ Daniel E. Glatter

General Counsel and Secretary

Att.:

Exhibit A

Exhibit B
EXHIBIT A

Amendments to the Rulebook & Compliance with Core Principles

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.

Tradition 

SEF 

Platform 

Supplement 

1 (“Trad-X 

Interest 

Rates 

Trading 

Platform”):

Appendix 1 

Sections

4(4) and 

7(10)

Modifications to Appendix 1 to reflect a minimum tick size 

increment change from one-eighth (0.125) to one-sixteenth of a 

basis point (0.0625) for USD Interest Rate Swap orders 

submitted to the Trad-X order book and conforming amendments 

for implied orders and rounding conventions for orders priced in 

decimals.

The modifications to the Trad-X 

Platform Supplement 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

Redline Version of Tradition SEF Rulebook
TRADITION SEF PLATFORM SUPPLEMENT 1

“TRAD-X” INTEREST RATES 

TRADING PLATFORM

(“Trad-X Platform”)

This Tradition SEF Platform Supplement to the Tradition SEF Rulebook, (the 

“Rulebook”) sets out the additional terms and conditions which shall apply exclusively 

to participation in and trading on the Platform and should be read in connection with the 

Rulebook.

July 21, 2020April 2, 2019

Version 1.43
TABLE OF CONTENTS

Page

S1-i

DEFINITIONS..........................................................................................................................................1

CHAPTER S1-1 RULES FOR INTEREST RATES ASSET CLASS.......................................................3

RULE S1-101 Precedence of Rules.............................................................................................3

RULE S1-102 Designation of Clearing House .............................................................................3

RULE S1-103 House Limits and Order Size Collar ....................................................................3

RULE S1- 104 The Trad-X Order Book.............................................................................3

RULE S1-105 USD Interest Rate Swaps and Request for Continuous Stream. ...........4

CHAPTER S1-2 PARTICIPATION IN THE PLATFORM ........................................................................5

RULE S1-201 Application Procedure...........................................................................................5

RULE S1-202 Eligibility ................................................................................................................5

RULE S1-203 Duties and Responsibilities of Participants...........................................................5

RULE S1-204 Access to the Trad-X Platform..............................................................................5

CHAPTER S1-3 TRADING RULES........................................................................................................6

RULE S1-301 Trading Days, Orders, Order Book and Clearing & Settlement............................6

RULE S1-302 Crossing of Pre-Arranged Customer Orders ........................................................6

RULE S1-303 Error Trades..........................................................................................................6

RULE S1-304 System-Related Error Trades ...............................................................................6

RULE S1-305 Suspension of Trading..............................................................................7

RULE S1-306 Market Surveillance & Operations............................................................8

APPENDIX 1 - TRAD-X PRODUCTS: USD INTEREST RATE SWAPS................................................9

APPENDIX 2 - CME/LCH AUCTIONS..................................................................................................15

APPENDIX 4 – TRAD-X PRODUCTS: EURO INTEREST RATE SWAPS..........................................17
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

TRADITION SEF PLATFORM SUPPLEMENT 1

(Trad-X PLATFORM)

This Tradition SEF Platform Supplement 1 to the Tradition SEF Rulebook, (the “Rulebook”) sets out the 

additional terms and conditions which shall apply exclusively to participation in and trading on the Trad-X 

Platform (“Trad-X Platform”) and should be read in connection with the Rulebook. When used herein, the 

term Participant refers only to a Participant who has been granted Trading Privileges on the Trad-X 

Platform by Tradition SEF, and the terms Customer, Broker Firm, Authorized Trader and Authorized 

Broker refer only to such Persons who have been granted access to the Trad-X Platform by such 

Participant.

DEFINITIONS

In addition to the Definitions as set forth in the Rulebook, the following Definitions shall be applicable to 

this Tradition SEF Platform Supplement 1.

“Auction” means the functionality promulgated on the Trad-X Platform for an Order matching facility and 

for defined periods to be determined by Tradition SEF in accordance with the Rules, during which 

Participants and Customers may submit Orders to the Auction Platform to be matched against other 

Orders, but provided that ongoing market data dissemination shall not be made in respect of submitted 

Orders, unless and until such Order is matched with another Order submitted to the Trad-X Platform.

“BBO” means Best Bid and Offer.

“CCP Auction” means an Auction run on a Auction Platform which involves the matching and execution 

of identical Swaps in opposing directions with opposing central counterparty Clearing Houses (CCPs), so 

as to allow Participants and Customers to reconcile outstanding positions in different CCPs and manage 

their collateral exposure with such CCPs.

“CME” means a Chicago Mercantile Exchange owned and operated Clearing House with which Tradition 

SEF has entered into a clearing access agreement that provides clearing and settlement services in 

relation to Swaps.

“Combination Order” means an Order which states that two or more Orders must be executed 

simultaneously. 

“Electronically Streamed Liquidity” means Orders received by Tradition SEF via electronic means into 

the Trad-X Platform Order Book or Request for Continuous Stream functionality.

“House Limit Function” means the technological function in the Trad-X Platform which operates to 

provide Participants that are Clearing Firms with the ability to allocate a notional-based, daily, resettable 

limit that controls the maximum amount of cumulative notional value of Trades which a Participant that is 

a Clearing Firm can execute through the Trad-X Platform for its own account within a given Trading Day 

(the “House Limit”). As Trades are entered into, with such Clearing Firm as a counterparty, the notional 

value of the legs of such Trades are deducted from the Clearing Firm’s House Limit until such House 

Limit is exhausted, from which point Orders from that Clearing Firm will be blocked by the Platform. For 

the avoidance of doubt, if an Order is placed by a Clearing Firm which, if executed against, would breach 

the House Limit of such Participant, the Trad-X Platform will block such Order.

“LCH” means an LCH owned and operated Clearing House with which Tradition SEF has entered into a 

clearing access agreement that provides clearing and settlement services in relation to Swaps.

“Order Input Collar” means the technological function in the Trad-X Platform which operates to prevent 

an Order being entered into the Platform by a Participant or a Broker Firm acting on behalf of a 

Participant or Customer, and so reject such Order, where the Order is more than 5bps through the then 

current mid-price on the Trad-X Platform in the relevant tenor. In the absence of a then current mid-price 

on the Trad-X Platform, the 5bps will be measured by reference to the Trad-X Curve. For the avoidance 

of doubt, the Participants acknowledge that the Order Input Collar will not prevent Combination Orders 

which themselves would have been prevented by the Order Input Collar had they been entered initially by 
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

the Participant but which instead are triggered by the entering of an initial order which is not itself 

prevented by the Order Input Collar.

“Order Size Collar” means the technological function in the Trad-X Platform which operates to prevent 

an Order being entered into the Platform by a Participant or a Broker Firm acting on behalf of a 

Participant or Customer, and so reject such Order, where the Order is more than the maximum size in the 

relevant product and tenor.

“Request for Continuous Stream” or “RFCS” means the transmission of a request by a Participant or 

Customer to another Participant wishing to receive a constant electronic market stream in specified 

products and tenors. Each responder to such request has a right, but not an obligation to provide a 

stream to the requesting Participant or Customer. A RFCS response will be active and constant during 

hours while the Trad-X Platform is open for trading until such time as the provision of the stream request 

is revoked by either Participant.

“Trad-X Curve” means the yield curve maintained and developed by the Trad-X Platform.

“Trad-X Products” means the Required Transactions and Permitted Transactions admitted to trading on 

the Trad-X Platform from time to time and as described in Appendix 1 to this Platform Supplement.

“Trad-X Platform User Agreement” means the Trad-X Platform User Agreement governing access by 

Participants to the Trad-X Platform.

“Product Transaction” or “Trade” means a matched Swap transaction in one of the Trad-X Products.
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

CHAPTER S1-1

RULES FOR INTEREST RATES ASSET CLASS.

RULE S1-101 Precedence of Rules

For the avoidance of doubt, any Rule contained in this Product Supplement, to the extent that there is any 

conflict with the Tradition SEF Rulebook, shall take precedence over inconsistent provisions in the 

Rulebook when associated with business conducted on the Trad-X Platform.

RULE S1-102 Designation of Clearing House 

LCH and CME each are designated as a Clearing House for the Trad-X Products and may, except as 

described in a Product Annex, clear all Product Transactions concluded in the Trad-X Platform until such 

time as they may be replaced or joined by another Clearing House pursuant to the terms of these Rules. 

RULE S1-103 House Limits and Order Size Collar 

In order to satisfy the requirements described in Rule 704(c) of the Rulebook, Tradition SEF shall put in 

place and maintain the House Limits and Order Size Collar functionalities for the Trad-X Platform.

Rule S1-104 The Trad-X Order Book

(a) Order Entry

(1) Electronic Orders. An Order may be submitted by electronic means directly to the Trad-X 

Platform Order Book by a Participant, a Customer authorized by a Participant, or by a 

Broker Firm authorized by a Participant to act on their behalf.

(2) Non-Electronic Orders. An Order for a Permitted or Required Transaction, other than an 

Order described in (1) above, may be submitted by a Participant or Customer or a Broker 

Firm Participant that is authorized by such Participant or Customer to act on their behalf. 

Such orders may be submitted to the Trad-X Platform either directly through manual 

interaction with a Platform GUI or via communication with a SEF Execution Specialist by 

such means as voice, IM, or email.

(3) Voice RFQ. A request for a response on an interest for a Required Transaction may be 

made by a Participant, or a Customer authorized by a Participant, or a Broker Firm 

Participant who is registered with the Tradition SEF and is authorized by a Participant or 

Customer to act on their behalf. Upon receipt of an RFQ the SEF Execution Specialist 

shall manage the RFQ process pursuant to Rule 507 of the Rulebook.

(4) Voice Work-Up

(i) At the point of execution of a Trade on the Trad-X Platform, either of the 

Participants or Customers who are counterparties to the Trade can request a 

work-up of the Trade at the same price and with the same terms as the Trade..

(ii) Should one Participant or Customer request a work-up, the opposing Participant 

or Customer to the original Trade will be given priority in the work-up process on 

the basis that no existing Order in the Order Book presently meets the execution 

price of the original Trade.

(iii) Should the opposing counterparty decline the opportunity to participate in the 

work-up process, and the work-up request is still valid, the offer of a work-up will 

be extended to all other Participants on the Trad-X Platform.

(iv) Should no Participant in the Platform accept the offer of work-up, the work-up 

process at that point shall be terminated.

(b) Subject to this Tradition SEF Platform Supplement 1 and as set out in associated Appendices 

contained herein and other relevant provisions of the Rules in the Rulebook, the Trad-X Platform 

will display all prices and automatically selects the best price in terms of highest bid and lowest 

offer prices and if there are two identical bid or offer prices then priority will strictly be given to the 
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

earlier price submitted to the Trad-X Platform. An Order is valid until removed either by the 

Participant who submits it to the Trad-X Platform or at the end of the Trading Day. In accordance 

with Rule 505 of the Rulebook, when Product Transactions are matched in the Trad-X Platform 

by a ‘bid’ Order being matched against an ‘offer’ Order or an ‘offer’ Order being matched against 

a ‘bid’ Order, a Trade will be deemed executed between the parties to the Product Transaction 

upon the terms of the matched ‘bid’ and ‘offer’. The point of matching of ‘bid’ and ‘offer’ by the 

Trad-X Platform shall be the definitive point at which there is an executed, valid and final Trade 

on the Trad-X Platform (subject to any other applicable provision of these Rules including, but not 

limited to, provisions dealing with error Trades). Following deemed execution of a Trade Tradition 

SEF shall submit the Product Transaction for clearing at a Clearing House in accordance with 

Chapter 7 of the Rulebook.

(c) Parties to transactions in Trad-X Products shall remain anonymous prior to the matching of a 

Trade. Tradition SEF shall promptly, following matching of a cleared Trade on the Trad-X 

Platform, provide each Participant or Customer who is a party to such cleared Trade with 

electronic confirmations containing all relevant information on that Trade.

(d) For bilateral uncleared transactions on the Trad-X Platform, Tradition SEF shall promptly, 

following matching of a bilateral uncleared Trade, provide each Participant or Customer who is a 

party to such uncleared Trade with electronic confirmations containing all relevant information on 

that Trade. 

Rule S1-105 USD Interest Rate Swaps – Request for Continuous Stream (“RFCS”) 

(a) RFCS functionality is only available by electronic means (API or GUI).

(b) RFCS functionality is separate and distinct from the Order Book. 

(c) Participants utilizing the RFCS functionality shall have the ability during market hours to stream 

electronic bids and offers to other Participants in the form of electronic pricing that is based on a 

request to receive a price stream (RFCS). Participants receiving a RFCS are permitted, but not 

obligated to provide prices to a RFCS.

(d) For a transaction to occur, both Participants to a RFCS (i.e. buyer and seller) must request and be 

accepted by the other Participant to receive price streams and be able to execute on them.

(e) Participants connecting to the RFCS service will be able to view all prices being provided to the 

service. However, Participants are prevented from executing on a price from a Participant that they 

have not requested a stream from or that has not been accepted as a reciprocal requestor. In an

instance where a Participant attempts to execute on a price from a party that has not been mutually 

accepted through the RFCS process, no execution between such parties will occur and such 

Participant will receive a “NO OPPOSING MARKET” message. 

(f) Each RFCS participant must request a minimum of three (3) counterparty streams at any given time.
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

CHAPTER S1-2

PARTICIPATION IN THE PLATFORM

RULE S1-201 Application Procedure

In addition to the Participant application process set forth in Rule 303 of the Rulebook, Participants shall

be required to have in place a Trad-X Platform User Agreement

RULE S1-202 Eligibility

In addition to the Participant Criteria requirements set forth in Rule 302 of the Rulebook, an applicant to 

participate on the Trad-X Platform must have technical and organizational facilities sufficient (in the 

opinion of Tradition SEF) for the orderly settlement of Product transactions to be assured and must meet 

the technical requirements for connection to the Trad-X Platform. Tradition SEF must be satisfied that the 

applicant has or will have sufficiently completed conformance testing prior to conducting business on the 

Trad-X Platform. 

RULE S1-203 Duties and Responsibilities of Participants

As set forth in Rule 402 of the Rulebook.

RULE S1-204 Access to the Trad-X Platform

As set forth in Chapter 3 of the Rulebook.
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

CHAPTER S1-3

TRADING RULES

RULE S1-301 Trading Days, Orders, Order Book and Clearing & Settlement 

Details of Trading Days, Orders, Order Book and clearing & settlement specifications for each Trad-X 

Product is set forth in this Supplement and the applicable Product Appendix.

RULE S1-302 Crossing of Pre-Arranged Customer Orders

In connection with an Order for a Trad-X Product deemed to be a Required Transaction by the CFTC, an 

Authorized Trader or Authorized Broker acting on behalf of a Participant who seeks to execute against its 

Customer’s Order, or seeks to execute two of its Customers’ Orders against each other through the Order 

Book, following some form of pre-arrangement or pre-negotiation of such orders, must first enter the first 

party’s Order, allow such Order to be exposed to the market for a minimum of fifteen (15) seconds, prior 

to entering the Pre-Arranged opposing Order. During the exposure period, all Tradition SEF Participants 

may transact on the first party’s order.

RULE S1-303 Error Trades

(a) Product Transactions effected through the Trad-X Platform on behalf of a Participant or Customer 

by their Authorized Trader, or by their Broker Firm’s Authorized Broker, or by a Tradition SEF 

Execution Specialist shall be binding on such Participant or Customer subject to Rule 538 of the 

Tradition SEF Rulebook or the Trad-X Platform User Agreement

(b) Notwithstanding the foregoing, Tradition SEF may cancel a Trad-X Product Transaction in 

accordance with the policy set out in Rule S1-304.

RULE S1-304 System-Related Error Trades

(a) Tradition SEF may unilaterally cancel a Trad-X Product Transaction where such Product 

Transaction constitutes a “System-Related Error Trade”.

(b) For the purpose of this Rule S1-304, a System-Related Error Trade shall be deemed to have 

occured where, due to a malfunction of the Trad-X Platform, a Trad-X Product Transaction is 

entered into:

(1) in the name of a Participant or Customer without the knowledge or authority of such a 

Participant or Customer;

(2) by Participant’s or Customer’s Authorized Trader, or by their Broker Firm’s Authorized 

Broker, after a notification to disable such Authorized Trader’s or Authorized Broker’s 

access to the Trad-X Platform has been received by Tradition SEF in accordance with 

the applicable procedures set out in the Trad-X Platform User Agreement;

(3) as a result of an order entering the Trad-X Platform as a result of a failure of the Order 

Input Collar; or

(4) which is manifestly erroneous.

(c) In the event that Tradition SEF becomes aware of a System-Related Error Trade or is notified by 

a Participant of a System-Related Error Trade in accordance with this Rule S1-304 and has 

determined to cancel a Trad-X Product transaction pursuant to this Rule S1-304, Tradition SEF 

shall issue a notice to all affected Participants specifying the affected counterparty(ies), 

Transaction details and timestamps (a “System-Related Error Trade Cancellation Notice”). In 

order for the procedures in this Rule S1-304 to apply, Tradition SEF must issue a System-Related 

Error Trade Cancellation Notice as soon as practicable following the System-Related Error Trade 

coming to its attention and, no later than two (2) hours before the end of the operating times for 

the applicable Clearing House (as may set forth in the rules and procedures of such Clearing 

House) on the Trading Day on which the System-Related Error Trade is alleged to have occurred.
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

(d) Any notification relating to a System-Related Error Trade must be made by a Participant to 

Tradition SEF at least 30 minutes before the cut-off time for Tradition SEF to send the SystemRelated Error Trade Cancellation Notice as set out in paragraph (c):

(1) by email to the Tradition SEF dedicated cancellation email address at 

trading.operations.us@tradition-na.com with a copy to 

trading.operations.us@tradition.com or, where communicated by phone, then 

confirmed by email promptly (and in any event no later than ten (10) minutes after the 

end of such phone communication); and

(2) all communications must be from a Participant’s Authorized Representative.

(e) All notifications from Participants relating to a System-Related Error Trade must contain:

(1) Participant’s primary contact details (name and direct line);

(2) all specific details of the Trade(s) ;

(3) timestamps for each Trade; and

(4) Participant’s reason for considering the Trade to be a System-Related Error Trade.

(f) Within thirty (30) minutes after the issue of a System-Related Error Trade Cancellation Notice by 

Tradition SEF, the Participants or Customers party to the relevant Product Transaction may, 

jointly, agree that the Product Transaction does not constitute a System-Related Error Trade (a 

“Good Trade”). Good Trades shall not be cancelled but all System-Related Error Trades shall be 

cancelled by Tradition SEF in accordance with this Rule S1-304.

(g) Where a System-Related Error Trade is to be cancelled, then Tradition SEF shall notify the 

counterparty(ies) of the cancellation of the Trade, the Trade shall be cancelled and a cancellation 

notice sent out to all Participants in respect of each such cancelled Trade. 

(h) No handling charge will be payable in respect of a cancellation caused by a System-Related Error 

Trade.

(i) If there is insufficient time in the Trading Day for any of the provisions of this Rule S1-304 to be 

carried out, Tradition SEF and the relevant Participants shall use all reasonable endeavors 

(including within and in accordance with the rules of the applicable Clearing House) to ensure that 

such procedures are completed prior to the commencement of trading on the next Trading Day 

or, if this is not possible, as soon as practicable after commencement of trading on the next 

Trading Day after the Trading Day on which the error event occurred.

(j) Where a System-Related Error Trade relates to an order which forms part of a Combination 

Order, all orders that form part of that Combination Order shall be cancelled in accordance with 

the error trade process set out in this Rule S1-304.

Rule S1-305 Suspension of Trading

a) Tradition SEF may at any time suspend trading in whole or in respect of one or more Financial 

Product types, if it in its discretion considers such action necessary having regard to market 

conditions. Tradition SEF shall revoke the suspension of trading in whole or in respect of one or 

more Financial Product types if, in its opinion, the reason for such suspension has ceased to 

exist.

b) The decision of Tradition SEF regarding the suspension of trading of a Financial Product type is 

generally made after the end of the main trading phase and shall be made public to all 

Participants or Customers by electronic means prior to the commencement of the following 

Trading Day. 
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

c) If trading in specific Financial Product types is suspended in whole or in part, no new orders or 

prices may be entered in respect of such Financial Product type for the duration of the 

suspension. Tradition SEF may, in the event of a suspension of trading, issue different 

instructions on a case-by-case basis.

Rule S1-306 Market Surveillance & Operations

a) Tradition SEF shall perform surveillance pursuant to the Rulebook and the Tradition SEF 

Compliance and Surveillance Manual.

b) Tradition SEF shall enforce compliance with these Rules and may take all measures necessary to 

ensure orderly trading and the smooth operation of the System.

c) In order to ensure orderly system functionality, the commencement of trading may, at the order of 

Tradition SEF, be postponed for the entire System or trading hours may be extended or 

shortened accordingly.

d) In the event of technical problems, Tradition SEF may, for individual or all Participants or 

Customers, temporarily suspend access to or trading in the System.

e) In the event of measures being taken which materially affect the operation of the System, the 

Participants or Customers affected thereby shall, to the extent possible, be promptly notified via 

the System or, in the case of a system failure, by other suitable electronic means.

f) If participation in trading on the Trad-X Platform is not possible to individual Participants or 

Customers due to individual technical disruptions, the System shall continue to be available to 

other trading Participants or Customers.
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

APPENDIX 1 - TRAD-X PRODUCTS: USD INTEREST RATE SWAPS

1 Interest Rate Swaps – product types

(1) The following product types shall be eligible for admission to and capable of being traded on the 

Trad-X Platform and may be modified by Tradition SEF from time to time: 

(a) USD Spread Over these are the combination spot dated interest rates swaps 1 to 50 

years Semi-Annual bond basis (30/360) on the fixed side versus 3 mth LIBOR (reference 

page LIBOR01) on the floating side dealt with of a hedge of benchmark treasuries of 

corresponding size; and

(b) USD Interest Rate Swaps 1 to 50 years Semi-Annual bond basis (30/360) on the fixed 

side versus 3 mth LIBOR (reference page LIBOR01) on the floating side;

2 USD Interest Rate Swaps – Credit Matrix Risk Based Limit Management Functionality

(1) The Trad-X Platform shall provide a risk-based management tool (the “Credit Matrix”) to provide 

functionality for Participants to manage, in accordance with this paragraph 2, risk limits in respect 

of its trading activities on the Trad-X Platform and/or the trading activities of its Customers.

(2) Full details and functional descriptions of the Credit Matrix is available to Participants of Tradition 

SEF and can be made available in the form of the Trad-X technical document entitled “Trad-X 

Member Management Console” (version 1.2 dated 26 March 2014 as may be updated from time 

to time by Tradition).

(3) By way of summary, the Credit Matrix shall provide the following functionality:

(a) “House Limit”: a maximum value (assigned by the Participant and/or Clearing Firm by 

reference to (i) Gross Notional; (ii) Gross DV01; or (iii) the stricter of Gross Notional and 

Gross DV01) of Transactions which the Participant may execute on the Trad-X Platform 

on a given Trading Day. Such “House Limit” shall include Transactions entered into by 

Customers of that Clearing Firm.

(b) “House Limit Kill Switch”: a control toggle allowing a Clearing Firm to disable all trading 

activity for the Clearing Firm and its Customers, overriding any risk limit values in place 

for that Clearing Firm. This will not affect Transactions entered into prior to activation of 

the House Limit Kill Switch.

(c) “CCP Limits”: a maximum value (assigned by the Clearing Firm by reference to (i) DV01; 

(ii) Notional; or (iii) the stricter of DV01 and Notional, and in each case by further 

reference to (a) Gross; (b) Net; or (c) the stricter of Gross and Net) of Transactions which 

the Participant may execute on the Trad-X Platform in relation to a given Clearing House. 

Once the limit is reached, no further Transactions which are to be cleared by that 

Clearing House will be permitted.

(d) “CCP Kill Switch”: a control toggle allowing a Clearing Firm to disable all trading activity 

on the Trad-X Platform for the Participant and its Customers in relation to activity with a 

particular Clearing House. This will not affect Transactions entered into prior to activation 

of the CCP Kill Switch.
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

(e) “Clearing Firm-to-Clearing Firm Risk Limits” (aka “FCM-to-FCM Limits” or “Bilateral 

Limits”): a fully customisable set of maximum values, on a Participant-by-Participant 

basis (assigned by a Clearing Firm by reference to (i) DV01; (ii) Notional; or (iii) the 

stricter of DV01 and Notional, and in each case by further reference to (a) Gross; (b) Net; 

or (c) the stricter of Gross and Net), of Transactions which the Participant may execute 

on the Trad-X Platform in relation to a given Participant.

(f) “Clearing Firm-to-Clearing Firm Kill Switch” (aka “FCM Kill Switch”): a control toggle 

allowing a Clearing Firm to disable all trading activity for the Clearing Firm on the Trad-X 

Platform in relation to a given Clearing Firm. This will not affect Transactions entered into 

prior to activation of the FCM Kill Switch.

(g) “Customer Limits”: a fully customisable set of subordinated credit maximum values, on a 

Customer-by-Customer basis (assigned by a Clearing Firm by reference to (i) DV01; (ii) 

Notional; (iii) Initial Margin; or (iv) the stricter of DV01, Notional and Initial Margin, and in 

the case of DV01 or Notional by further reference to (a) Gross; (b) Net; or (c) the stricter 

of Gross and Net (Initial Margin limits can only be Gross)), of Transactions which the 

Clearing Firm’s given Customer may execute on the Trad-X Platform.

(h) “Customer Kill Switch”: a control toggle allowing a Clearing Firm to disable all trading 

activity on the Trad-X Platform for (i) a given Customer; or (ii) all its Customers. This will 

not affect Transactions entered into prior to activation of the FCM Kill Switch.

(i) Customisable Alerts: a set of fully customisable alerts to alert Clearing Firms in relation to 

risk limit usage of (i) House Limit; (ii) CCP Limits; (iii) Bilateral Limits (on an “ALL” or 

“Clearing Firm-by-Clearing Firm” basis); and (iv) Customer Limits (on an “ALL” or 

“Customer-by-Customer” basis) which can be set for values between 1% and 100% of 

assigned credit values.

3 USD Interest Rate Swaps - Orders

(1) Prices can be offered for certain Order types (as indicated on the Trad-X Platform website), which 

shall remain valid, until changed or cancelled by the Participant or Customer. Unless the 

Participant or Customer elects otherwise, orders entered in the Trad-X Platform and not matched 

will be automatically cancelled at the end of the Trading Day.

(2) Order Types and Price Conditions

(a) Limit: The order will be executed at a price that is no worse than that specified by the 

Participant or Customer.

(b) Market: The order will execute against any available orders in the opposite side of the 

book, on a price-time priority, until the order is fully executed or all liquidity exhausted, 

whichever comes first. Persistent market orders (i.e. Day, GTC, etc) will not be accepted. 

For the avoidance of doubt, market orders will only be accepted if their Time In Force is 

FOK/IOC.

(c) Linked: The orders will be priced with reference to the yield of a benchmark treasury 

plus/minus a spread specified by the Participant or Customer. Linked orders cannot be 

FOK/IOC.
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CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

(d) Trade at Settlement (“TAS”): Is an order for a fixed volume in a contract, at a price or 

premium equal to the daily settlement price or index fixing price, or a specified differential 

above or below the daily settlement price or index fixing price, for the contract on a 

trading day. The actual TAS transaction price or premium is determined subsequent to 

the transaction, based upon the daily settlement price or index fixing price of the contract.

(e) Disregard Tape (“DRT”): Absent any restrictions, a DRT (Not-Held Order) means any 

Order giving a Person complete discretion over price and time in execution of an Order, 

including discretion to execute all, some or none of this Order.

(f) Split the Spread Order (“Split the Spread”): Enables Participants or Customers to Split 

the Spread of bid and offer prices and trade at the mid-point between two Participant’s 

opposing Limit Orders, thereby allowing Participants to “meet in the middle” of the bidoffer spread.

(3) Time In Force:

(a) Day: The order will be valid during the current normal trading session only.

(b) GTD: The order will participate in all normal trading sessions incurred until and including 

the specified date. The order is cancelled at the end of the Trading Day on which it was 

submitted. 

(c) GTT: The order will participate in all normal trading sessions until the date-time specified 

is reached, at which time the order will be cancelled, even if the current (active) trading 

session has not finished. The order is cancelled at the end of the Trading Day on which it 

was submitted.

(d) GTC: The order will participate in all normal trading sessions until cancelled by the 

Participant. The order is cancelled at the end of the Trading Day on which it was 

submitted.

(e) IOC: All or part of the order will be executed immediately upon receipt. Any portions not 

executed immediately will be automatically cancelled.

(f) FOK: The order will be executed in full immediately upon receipt, or cancelled. For the 

avoidance of doubt, if the order is not executable in full and immediately it will be 

cancelled, but full executions may be achieved through more than one fill.

(g) Split the Spread: A Participant or Customer can enable a Split the Spread flag with their 

Limit bid or offer in the Order Book. If the best opposing Limit bid or offer has also 

enabled a Split the Spread flag on the order, Trad-X will match the Split the Spread 

Orders by filling half of the matching Order size at the bid level and half the Order size at 

the offer level. This creates an average price for the resulting transaction in the middle of 

the bid-offer spread. Split the Spread Order flags are invisible to the market except to the 

Participant or Customer entering the Split the Spread Order. Split the Spread 

functionality will only operate when a market is being quoted at a width of the market’s 

minimum price fluctuation.

(4) In relation to this paragraph 3, note that:

(a) Orders priced at the market will only be accepted if their “Time In Force” is FOK or IOC;

(b) Orders priced at a Limit Price will be accepted with any of the above “Time In Force” 

values, including IOC/FOK; and

(c) Linked orders will only be accepted if they have a “Time In Force of Day”, “GTD”, “GTT” 

or “GTC”.
S1-12

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

4 USD Interest Rate Swaps - Order Book

(1) The Order Book contains all Orders entered into the Trad-X Platform Order Book by Participants, 

Customers, SEF Execution professionals or Broker Firms acting on behalf of Participants or 

Customers. Participants, Customers or Broker Firms may view in the Order Book all orders per 

term, and Trad-X Product Transactions including information as to the contract size at point of 

execution. Subject to the operational characteristics set forth in Rule S1-104 of this Trad-X 

Platform Supplement, if an Order is matched it will be removed from the queue and only live 

Orders will be shown in the Trad-X Platform. Orders not matched by the end of the Trading Day 

will be cancelled and Participants and Customers must therefore re-enter their Orders into the 

Trad-X Platform on the following Trading Day or specify the period of time they would like the 

Order to remain in the Trad-X Platform when entering the Order.

(2) Notwithstanding the default price/time priority rule set out in Rule S1-104(b) of this Trad-X 

Platform Supplement, the Trad-X Platform operates a “Spread Over Stack Priority” rule, to 

reward Participants and Customers in relation to USD Spread Over trading.

(3) The Spread Over Stack Priority rule has the following characteristics:

(a) Where a Participant or Customer Trades USD Spread Over (fill or partial-fill), in a given 

instrument, in at least the minimum screen size as set forth in Appendix 3, it can enter a 

new order for such instrument, at the then-current Platform BBO price, with such order 

taking immediate top-of-the-stack priority notwithstanding existing orders at the same

price which were entered earlier.

(b) The Participant or Customer may only take advantage of the Spread Over Stack Priority 

rule within 5 seconds from its last Trade. A new order entered after the 5 seconds time 

period will have the normal price/time priority stack position.

(c) Priority is always given to the last Participant or Customer who traded that instrument.

(d) A Participant or Customer cannot take advantage of the Spread Over Stack Priority rule if 

the applicable instrument Trades again before that Participant or Customer has taken 

advantage of the rule by entering a new order at BBO. Any order entry by that 

Participant or Customer would be subject to the normal price/time priority stack position.

(4) Implied Price Display: in line with market convention, and until such point as Applicable Law 

requires otherwise, where a Participant’s or Customer’s interaction with the Trad-X Platform 

results in the creation of an “implied order” (i.e. where two or more orders are created from a 

single originating order input by a Member) which is valued in 1/32nd16ths or 0.0625 03125 (the 

“thirty secondsSixteenths Price”) the price of such implied order shall be displayed by the Trad-X 

Platform to the nearest 1/816th or 0.1250.0625, by rounding down (in the case of a implied bid) or 

by rounding up (in the case of an implied offer) to the nearest 1/168th or 0.125 0625 (the “Eighths 

Sixteenth Price”). Where such implied orders (as resting orders in the Order Book) are 

aggressed by a Member at the Eighths Sixteenths Price, the Trad-X Platform will automatically 

execute the transaction at the (price improved) Sixteenths thirty second Price.

5 USD Interest Rate Swaps - Clearing and Settlement

(1) The Trad-X Platform operates on the basis that Trad-X Product transactions shall be effected 

only between Participants or Customers who have met the Participant or Customer criteria and 

completed the Participant or Customer application process as set out in Rules 302, 304 and 305

of the Rulebook successfully.

(2) The Trad-X Platform functions enable the Participants and Customers to negotiate the contract 

components of the relevant Trad-X Product transaction.
S1-13

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

(3) To the extent permitted by Applicable Law, both Participants or Customers, as applicable, to a 

matched Product transaction may, jointly, instruct a clearing connectivity provider to route such 

Product transactions to direct bilateral settlement between such Participants or Customers, as 

applicable, and not for clearing via a Clearing House.

6 USD Interest Rate Swaps - Trading Days and timings

(1) Trading on the Trad-X Platform for USD Interest Rate Swaps shall take place on each Business 

Day, other than such days deemed to be New York holidays. Tradition SEF reserves the right to 

determine additional Trading Days after prior announcement thereof to the Participants. For the 

purposes of this Rule 6.1, “Business Day” is every weekday that is not a holiday in New York. 

(2) Trading on the Trad-X Platform will be available between 03.00 and 17.00 (EST) or for such other 

periods as may be determined by Tradition SEF as set forth in a Participant Notice.

7 Order Management

(1) Trad-X’s operations team will have the authorization to cancel unmatched orders on behalf of a 

Participant or Customer, following authorization from that Participant’s Authorized Trader or an 

Authorized Broker acting on behalf of the Participant or Customer, in accordance with the Rules 

from time to time.

(2) SEF Execution Specialists cannot be held responsible for delays in carrying out a request by a 

Participant or Broker Firm that results in the Trade being filled electronically or a Trade being 

missed. The SEF Execution Specialists will use reasonable endeavors to fill the request in a 

responsible and timely manner. 

(3) A voice Order from a Participant’s Authorized Trader or a Broker Firm acting on behalf of a 

Participant or Customer to a SEF Execution Specialists to interact with a resting Bid or Offer in 

the Order Book (hybrid order) will not, in itself, be a guarantee to Trade. The SEF Execution 

Specialists will use reasonable endeavors to get the order filled.

(4) Wherever possible the Participant or Broker Firm acting on behalf of a Participant or Customer 

should specify rate, direction and size when submitting a voice order to be executed 

electronically. In the event that a size or rate is not specified a voice Order to hit the electronic 

price will result in the SEF Execution Specialists hitting the best bid or taking the best offer in 

following sizes:

 Spreadover SemiBond

2y 100 million 75 million

3y 75 million 50 million

5y 50 million 30 million

7y 30 million 20 million

10y 25 million 15 million

12y 20 million 10 million

15y 20 million 10 million

20y 20 million 10 million

30y 20 million 10 million

Notes: 

1. Size on curves are calculated on the longer leg.
S1-14

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

2. Sizes on butterflies are on the body and are therefore twice the above amounts (i.e.

5x7x10 would be 60 million).

(5) Minimum size on electronic orders are as set forth in Appendix 3 of this Trad-X Product 

Supplement.

(6) Spread Over Trades – Treasuries are automatically chosen to be crossed at the offer side of the 

treasury with the IRS rate being calculated automatically (to 5 decimal places). Lot sizes are 

calculated using standard market convention. Treasury details will be included on Markitwire 

confirmation for processing. For the avoidance of doubt, no Treasuries will be Traded on the 

Trad-X Platform and all Treasuries Trades will occur on different venues. 

(7) For default duration ratios on butterflies and spreads, all Participants agree to use Trad-X default 

duration calculator which is rounded down to the nearest USD 1 million.

(8) It is the Participants sole responsibility to monitor its own Electronically Streamed Liquidity. 

(9) Trad-X midpoint calculation – midpoints used by the Trad-X Platform will be calculated using the 

middle of the best bid/best offer spread regardless of size weighting.

(10) Rounding decimal places – The Trad-X Platform cannot modify orders submitted by Participants 

and require submission of orders with no more than 5 decimal places in 0.00125 000625

increments except that for Spread Over Trades minimum increments will be 0.002500125.

(11) All electronic Trades conducted on the Trad-X Platform will be identified on Markitwire by TRAD 

ESTP.(LDN) or TRAD ESNY (NYC).
S1-15

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

APPENDIX 2 - TRAD-X PRODUCTS: USD INTEREST RATE SWAPS AUCTIONS

1 CME/LCH CCP Auctions – timings, characteristics and process

(1) CCP Auctions allow Participants and Customers to enter orders to negotiate “switch” (or 

“spread”) trades in interest rate swaps (IRS) between LCH Clearnet (LCH) and CME 

Clearing (CME) CCPs. The auction prices will be quoted on the basis between the fixed 

rate of the LCH cleared swap and the fixed rate of the CME cleared swap.

(2) The CCP auctions will be conducted in the following manner and in conjunction with the 

Tradition SEF Rulebook: 

(3) USD CME/LCH CCP Auctions on Trad-X protocols:

(a) USD CME/LCH CCP Auctions start every day @ 10:30AM NYC time. 

(b) The session runs for 5 minutes.

(c) The auction will use IMM swap structure to facilitate compression at CCP level.

(d) IMM swap: Start date on the first future contract date, IMM rolls and IMM end date.

(e) The “execution price” is the basis between the fixed rate (Actual_360) of the LCH 

cleared IMM swap and the fixed rate (Actual_360) of the CME cleared IMM swap.

(f) Price of the first session will be communicated to participants by email before the 

auction process commences.

(g) The auction prices will be generated from TIRS (Tradition’s reference page on 

Bloomberg for this product) indicative mid markets just before the auction’s start. 

(h) Orders may be amended or cancelled during the auction session.

(i) Multiple buy and seller orders for the same auction are permitted. 

(j) Minimum execution sizes are the following: 

2 IMM(CME) v 2 IMM(LCH) – 100MM

3 IMM(CME) v 3 IMM(LCH) – 100MM

5 IMM(CME) v 5 IMM(LCH) – 100MM

7 IMM(CME) v 7 IMM(LCH) – 100MM

10 IMM(CME) v 10 IMM(LCH) – 100MM

12 IMM(CME) v 12 IMM(LCH) – 100MM

15 IMM(CME) v 15 IMM(LCH) – 100MM

20 IMM(CME) v 20 IMM(LCH) – 100MM

30 IMM(CME) v 30 IMM(LCH) – 100MM

(k) Trade unit tick sizes are in the increments of the above minimum execution sizes.

(l) Orders will be instantly matched on a first come, first served basis (Standard 

“Order Book” protocol). 

(m) The LCH cleared IMM swap will be executed at mid-market directly calculated from 

the Trad-X CLOB at the time of execution.

(n) Orders will be matched either partially (in minimum size) or fully and will remain in the 

Order Book awaiting the match until they are cancelled by the user or cancelled 

automatically at the end of the auction session.

(o) Trades will be reported immediately into the public Trad-X blotter.

(p) SEF Confirmations will be sent to trading counterparties via Markitwire.

(q) The auction service is fully integrated with the Trad-X Credit Matrix for pre-trade 

credit checking.

(r) Access is provided to all SEF Participants authorized to trade this product if or when 

requested.

(s) Orders can be submitted directly or via SEF Execution Specialist.
S1-16

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

AUCTION EXECUTION FEE IS SET FORTH IN THE CURRENT TRADITION SEF FEE SCHEDULE.
S1-17

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

APPENDIX 3 – USD INTEREST RATE PRODUCTS MINIMUM ORDER SIZES

Minimum sizes are as set forth below and maybe changed from time to time by Tradition 

SEF.

Maturities Spreadover SemiBond

2y 100 million 72 million

3y 75 million 48 million

4y 50 million 30 million

5y 50 million 29 million

6y 50 million 24 million

7y 30 million 20 million

8y 25 million 15 million

9y 25 million 15 million

10y 25 million 15 million

11y 25 million 13 million

12y 25 million 12 million

13y 20 million 10 million

14y 20 million 10 million

15y 20 million 10 million

16y 20 million 9 million

17y 20 million 9 million

18y 20 million 9 million

19y 20 million 8 million

20y 20 million 8 million

21y 20 million 10 million

22y 20 million 10 million

23y 20 million 10 million

24y 20 million 10 million

25y 20 million 10 million

26y 20 million 10 million

27y 20 million 10 million

28y 20 million 10 million

29y 20 million 10 million

30y 20 million 10 million

Notes:

1. USD Spread Over Orders are subject to a minimum size of 50k DV01 in 1/8 dollar price 

increments. Orders placed below the 50k DV01 size may be cancelled by Tradition SEF.

2. Size on curves are calculated on the longer leg of the structure.

3. Size on butterflies are calculated on the body of the structure.
S1-18

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

APPENDIX 4 – TRAD-X PRODUCTS: EURO INTEREST RATE SWAPS

1 Interest Rate Swaps – product types

(1) The following product types shall be eligible for admission to and capable of being traded on the 

Platform:

(a) Euro interest rates swaps 1 to 50 years annual bond basis (30/360) on the fixed side 

versus 3 mth EURIBOR (reference page EURIBOR01) on the floating side;

(b) Euro interest rates swaps 1 to 50 years annual bond basis (30/360) on the fixed side 

versus 6 mth EURIBOR (reference page EURIBOR01) on the floating side;

(c) 3mth v 6mth single currency basis spreads 1 to 50 years (traded as two swaps described 

above) with the spread between the fixed rates representing the spread dealt;

(d) BUND, BOBL and SCHATZ spreads are cockdated Euro interest swaps annual bond 

basis (30/360) on the fixed side versus 6 mth EURIBOR (reference page EURIBOR01) 

dated from the maturity of the futures contract maturing on the maturity of the “Cheapest 

To Deliver” of the contract (“Stub” at the front) dealt with a futures hedge of 

corresponding size, quoting the front two contracts.

2 EUR Interest Rate Swaps – Risk Based Limit Management Functionality

Same as Appendix 1, Rule 2.

3 EUR Interest Rate Swaps - Orders

As per Appendix 1, Rule 3.

4 EUR Interest Rate Swaps - Order Book

The Order Book contains all Orders entered in the Trad-X Platform by Participants, Customers, 

SEF Execution Professionals or Broker Firms acting on behalf of Participants or Customers. 

Participants, Customers or Broker Firms may view in the Order Book all orders per term, and 

Trad-X Product Transactions including information as to the contract size at point of execution. If 

an Order is matched it will be removed from the queue and only live Orders will be shown in the 

Trad-X Platform. Orders not matched by the end of the Trading Day will be cancelled and 

Participants and Customers must therefore re-enter their Orders into the Trad-X Platform on the 

following Trading Day or specify the period of time they would like the Order to remain in the 

Trad-X Platform when entering the Order.

5 EUR Interest Rate Swaps - Clearing and Settlement

As per Appendix 1, Rule 6.
S1-19

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

6 Interest Rate Swaps - Trading Days and timings

(1) Trading on the Platform for Euro Interest Rate Swaps shall take place on each Business Day, 

other than TARGET holidays. Tradition SEF reserves the right to determine additional Trading 

Days after prior announcement thereof to the Members. For the purposes of this Rule 6.1, 

“Business Day” means every weekday that is not a TARGET holiday.

(2) Trading on the Trad-X Platform will be available between 02.30 and 12.00 (EST) or for such other 

periods as may be determined by Tradition SEF as set forth in a Participant Notice.

7 EUR Interest Rate Swaps – Order Management

(1) Trad-X’s operations team or SEF Execution Specialists will have the authorization to cancel 

unmatched orders on behalf of a Participant or Customer, following authorization from that 

Participant’s Authorized Trader or an Authorized Broker acting on behalf of the Participant or 

Customer, in accordance with the Rules from time to time.

(2) SEF Execution Specialists cannot be held responsible for delays in carrying out a request by a 

Participant or Broker Firm that results in the Trade being filled electronically or a Trade being 

missed. The SEF Execution Specialists will use reasonable endeavors to fill the request in a 

responsible and timely manner. 

(3) A voice Order from a Participant’s Authorized Trader or a Broker Firm acting on behalf of a 

Participant or Customer to a SEF Execution Specialists to interact with a resting Bid or Offer in 

the Order Book (hybrid order) will not, in itself, be a guarantee to Trade. The SEF Execution 

Specialists will use reasonable endeavors to get the order filled.

(4) Wherever possible the Participant or Broker Firm acting on behalf of a Participant or Customer 

should specify rate, direction and size when submitting a voice order to be executed 

electronically. In the event that a size or rate is not specified a voice Order to hit the electronic 

price will result in the SEF Execution Specialists hitting the best bid or taking the best offer in 

following sizes:

2y 200 million

3y 150 million

5y 100 million

7y 75 million

10y 50 million

12y 25 million

15y 25 million

20y 25 million

30y 25 million
S1-20

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

Note: Size on curves are calculated on the longer leg. Size on butterflies are on the body.

(5) Minimum size on electronic orders will be Euro 10 million.

(6) Futures spreads (Bund/Bobl/Schatz) – futures crosses are automatically executed at the bid side 

of the futures contract and swap rate calculated automatically (to 5 decimal places) using the 

standard conversion factor. Lot size is calculated using standard market convention. Futures 

trades will be sent for manual processing to agree all details.

(7) For default duration ratios on butterflies and spreads, all Participants agree to use Trad-X default 

duration calculator which is rounded down to the nearest Euro 0.1million.

(8) It is the Participants sole responsibility to monitor its own Electronically Streamed Liquidity. 

(9) Trad-X midpoint calculation – midpoints used by the Trad-X Platform will be calculated using the 

middle of the best bid/best offer spread regardless of size weighting.

(10) Rounding decimal places – The Trad-X Platform cannot modify orders submitted by Participants 

and require submission of orders with no more than 4 decimal places in 0.0005 increments.

(11) All electronic Trades conducted on the Trad-X Platform will be identified on Markitwire by TRAD 

ESTP.(LDN).
S1-21

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

APPENDIX 6 – TRAD-X PRODUCTS: STERLING INTEREST RATE SWAPS

1 GBP Interest Rate Swaps – product types

(1) The following product types shall be eligible for admission to and capable of being traded on the 

Trad-X Platform:

(a) GBP 1y to 50y Semi/Semi and all combinations of spreads and ‘flies;

(b) GBP 1y to 50y 6v3s basis and all combinations of spreads and ‘flies (done 

as a single basis (floating/floating) swap); and

(c) GBP matched maturities of all liquid UK government gilts.

2 GBP Interest Rate Swaps – Risk Based Limit Management Functionality

(1) Same as Appendix 1, Rule 2.

3 GBP Interest Rate Swaps - Orders

As per Appendix 1, Rule 3.

4 GBP Interest Rate Swaps - Order Book

The Order Book contains all Orders entered in the Trad-X Platform by Participants, Customers, 

SEF Execution Professionals or Broker Firms acting on behalf of Participants or Customers. 

Participants, Customers or Broker Firms may view in the Order Book all orders per term, and 

Trad-X Product Transactions including information as to the contract size at point of execution. If 

an Order is matched it will be removed from the queue and only live Orders will be shown in the 

Trad-X Platform. Orders not matched by the end of the Trading Day will be cancelled and 

Participants and Customers must therefore re-enter their Orders into the Trad-X Platform on the 

following Trading Day or specify the period of time they would like the Order to remain in the 

Trad-X Platform when entering the Order.

5 GBP Interest Rate Swaps - Clearing and Settlement

As per Appendix 1, Rule 6.

6 GBP Interest Rate Swaps - Trading Days and timings

(1) Trading on the Platform for Sterling Interest Rate Swaps shall take place on each Business Day, 

other than such days when NYSE Liffe or the Clearing House is closed for business. Tradition 

reserves the right to determine additional Trading Days after prior announcement thereof to the 

Participants. For the purposes of this Rule 6.1, “Business Day” means every weekday that is not 

a holiday in London. 

(2) Trading on the Platform will be available between 03.00 and 12:00 (EST) or for such other 

periods as may be determined by Tradition SEF as set forth in a Participant Notice.
S1-22

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

7 GBP Interest Rate Swaps – Order Management

(1) Trad-X’s operations team will have the authorization to cancel unmatched orders on behalf of a 

Participant or Customer, following authorization from that Participant’s Authorized Trader or an 

Authorized Broker acting on behalf of the Participant or Customer, in accordance with the Rules 

from time to time.

(2) SEF Execution Specialists cannot be held responsible for delays in carrying out a request by a 

Participant or Broker Firm that results in the Trade being filled electronically or a Trade being 

missed. The SEF Execution Specialists will use reasonable endeavors to fill the request in a 

responsible and timely manner. 

(3) A voice Order from a Participant’s Authorized Trader or a Broker Firm acting on behalf of a 

Participant or Customer to a SEF Execution Specialists to interact with a resting Bid or Offer in 

the Order Book (hybrid order) will not, in itself, be a guarantee to Trade. The SEF Execution 

Specialists will use reasonable endeavors to get the order filled.

(4) Wherever possible the Participant or Broker Firm acting on behalf of a Participant or Customer 

should specify rate and size when submitting a voice order to be executed electronically. In the 

event that a size or rate is not specified a voice Order to hit the electronic price will result in the 

SEF Execution Specialists hitting the best bid or taking the best offer in following sizes:

2y 75 million

3y 75million

5y 30 million

7y 25 million

10y 15 million

12y 10 million

15y 10 million

20y 10 million

30y 10 million

Note: Size on curves are calculated on the longer leg. Size on butterflies are on the body.

(5) Minimum size on electronic orders will be GBP 1 million.

(6) For default duration ratios on butterflies and spreads, all Participants agree to use Trad-X default 

duration calculator which is rounded down to the nearest GBP 0.1million.

(7) It is the Participants sole responsibility to monitor its own Electronically Streamed Liquidity. 

(8) Trad-X midpoint calculation – midpoints used by the Trad-X Platform will be calculated using the 

middle of the best bid/best offer spread regardless of size weighting.
S1-23

CONFIDENTIAL TREATMENT REQUESTED BY TRADITION SEF, INC.

(9) Rounding decimal places – The Trad-X Platform cannot modify orders submitted by Participants 

and require submission of orders with no more than 5 decimal places in 0.00125 increments.

(10) All electronic Trades conducted on the Trad-X Platform will be identified on Markitwire by TRAD 

ESTP.(LDN).