Bennett Kirschner

TRADITION SEF, LLC General Counsel and Secretary

June 2, 2023 

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 40.2(a) Certification. Request for New Product Certification of 

Tradition SEF’s Interest Rate Swap Asset Classes Product Listing and non-substantive 

changes to IRS Product Listing

Tradition SEF Submission No. 2023-01 

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”) Regulations 40.2(a) Tradition SEF, LLC 

(“Tradition SEF” or “The SEF”) hereby notifies the Commission of revisions to the following:

Its Interest Rate Swap Asset Class Product Listing Terms and Conditions (the “IRS Product Listing Terms 

and Conditions”) with respect to the addition of the following interest rate index underlying the interest 

rate swaps offered for trading: CAD Overnight Repo Rate Average (CORRA); 

Redlined and clean versions of Tradition SEF Rulebook Appendix A is attached hereto as Exhibit A to 

reflect the changes. The effective date for these additions and revisions is June 20, 2023. 

Please note that Tradition SEF Submission No. 2023-01 includes the following revisions to the IRS 

Product Listing and Terms and Conditions: 

Appendix A:

• The statistics associated with Interest Rate Swaps has been updated.

• Canadian Overnight Repo Rate Average (CORRA) has been added to Section 2 of the Product List 

within Appendix A to the Tradition SEF Rulebook. 

Tradition SEF, LLC 32 Old Slip, 28th Floor, New York, NY 10005 212-791-4500 www.traditionsef.com
• Clearing information for the designated clearing organizations associated with Canadian Overnight 

Repo Rate Average (CORRA) swaps has been added to Section 5 of Appendix A to the Tradition 

SEF Rulebook. 

• Reference to Canadian Overnight Repo Rate Average (CORRA) has been added to Section 6 

within Appendix A to the Tradition SEF Rulebook. 

• Reference to Canadian Overnight Repo Rate Average (CORRA) has been added to Table 2 within 

Appendix A to the Tradition SEF Rulebook detailing the available currencies and the current 

publisher associated with each of the aforementioned reference indexes. 

Tradition SEF hereby certifies compliance with applicable provisions of the Act, including 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. In particular, the products listed in this submission 

adhere to Core Principles 3 (“Swaps Not Readily Susceptible to Manipulation”) and 7 (“Financial 

Integrity of Transactions”) and CFTC Rules 37.300-301 and 37.700-37.702. 

Herein, Tradition SEF demonstrates that the contracts listed for trading on Tradition SEF are not readily 

susceptible to manipulation as follows: 

CAD CORRA Swaps:

The following is a description of the Canadian Overnight Repo Rate Average (CORRA): 

The Canadian Overnight Repo Rate Average (CORRA) is a measure of the cost of overnight general 

collateral funding in Canadian dollars using Government of Canada (GoC) treasury bills and bonds as 

collateral for repurchase transactions (repos). The Bank of Canada calculates CORRA based on 

transaction-level repo data that Canadian government securities distributors, including primary 

dealers, and the six largest federally regulated financial institutions in Canada submit to the Investment 

Industry Regulatory Organization of Canada (IIROC) through the Market Trade Reporting System 

(MTRS). This approach makes CORRA robust, reliable and representative, similar to overnight risk-free 

reference rates published by other central banks. It also aligns CORRA with the Principles for Financial 

Benchmarks published by the International Organization of Securities Commissions. 

The CORRA calculation methodology was developed under the guidance of the Canadian Alternative 

Reference Rate Working Group (CARR), representing a wide range of market participants. It was also 

informed by CARR’s public consultations, held February to April 2019, on the methodology 

enhancements.
Tradition SEF hereby certifies that the products 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 product 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/news/), 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 bennett.kirschner@tradition.com. Please reference Tradition 

SEF Submission No. 2022-02 in any related correspondence. 

Sincerely,

Bennett Kirschner

General Counsel and Secretary

Att. 

Exhibit A
EXHIBITS 

A) Appendix A to Tradition SEF Rulebook

Interest Rate Swap Product Listing