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

October 19, 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(a) Required Certification AEGIS SEF, LLC

Amendment to Rulebook

Dear Sir:

Pursuant to Section 40.6(a) 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 Rulebook to enable a third method of execution. The 

rule amendment submission enables AEGIS SEF to accept pre-arranged or pre-negotiated trades 

which can be brought to the SEF for execution by a Broker Firm. This method of execution is 

consistent with other approved SEF Rulebooks. The Rule Amendments shall become effective 

10 days after this submission has been filed or immediately upon approval by the CFTC, 

whichever occurs first.

A concise explanation and analysis of the rules and their compliance with applicable provisions 

of the Act, including core principles and the Commission’s regulations, is attached hereto as 

Exhibit A. A copy of the Rulebook, Fee Schedule and Broker Firm Agreement are attached 

under separate cover as Exhibits B, C and D respectively. A redlined version of the Rulebook, 

Fee Schedule and Broker Firm Agreement are attached under separate cover as Exhibits E, F and 

G respectively. Exhibits D and G bear the designation “Confidential Treatment Requested by 

AEGIS SEF, LLC.”

This request for confidential treatment is made pursuant to Commission Regulations 40.8, as 

Exhibits D and G contain information that would reveal the trade secrets or confidential 

commercial or financial information of AEGIS SEF and its affiliates.

AEGIS hereby certifies that: (i) the amended rule complies 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 the rule.

Please contact the undersigned at 832-413-5973 or afurman@aegis-hedging.com with any 

questions regarding this matter.
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Andrew Furman

Chief Compliance Officer

AEGIS SEF, LLC

2829 Technology Forest Blvd

Suite 260

The Woodlands, TX 77381

Exhibit A – Explanation 

Amendment and Explanation Supporting Rule / Core Principle

Updating Definition of AEGIS-SEF 

Platform (1.5)

• Adding language to include Offline 

Execution Functionality

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Updating Definition of Broker Firm (1.18)

• Broadening the definition to allow 

Broker Firms to represent CEUs and 

Financial Counterparties that are not 

otherwise Participants on AEGIS SEF

• Added – Broker Firms may bring 

Permitted Offline Transactions to 

AEGIS SEF for execution

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

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

Updating Definition of Broker Firm 

Agreement (1.19)

• Clarifying that Broker Firm 

Agreements will cover the submission 

Permitted Offline Transactions in 

addition to the submission of Orders 

and transmission of RFQs.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Updating Definition of Customer (1.38)

• Broadening the definition of Customer 

to include Non-Participating 

Commercial End Users and NonParticipating Financial Counterparties 

(each of which must have signed a 

Broker Firm Agreement with the 

Broker Firm)

• Customer now includes any entity for 

whom a Broker Firm can execute for

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Including References to “Customers” 

throughout Rulebook

• Rulebook often includes references to 

“Participants, Broker Firms, and 

ISVs”

• With the updated definition of 

Customer, incorporation of Customer 

throughout the document subjects the 

NPFCs and NPCEUs to rules 

throughout the Rulebook

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Updating Definition of Designated 

Participant (1.41)

• Clarifying that Designated 

Participants can include NonParticipating Financial Counterparties

• Because swaps can be negotiated via 

any form of interstate commerce and 

Non-Participating Financial 

Counterparties are subject to the rules 

and jurisdiction of AEGIS SEF, a 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

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

Non-Participating Financial 

Counterparty is eligible to participate 

in a trade on the AEGIS SEF Platform 

Adding Definition of Execution Specialist

(1.54)

• Adding the ability of an AEGIS SEF 

employee to enter Permitted Offline 

Transactions and receive reports of 

Broker Firm recordkeeping and audit 

trail requirements

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Updating Definition of Financial 

Counterparty (1.57)

• Clarifying that Financial 

Counterparties can also pre-arrange or 

pre-negotiate a swap transaction in 

addition to participating in an Order or 

an RFQ.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Adding Definition of NPCEU or NonParticipating Commercial End User (1.80)

• Adding the ability for a Commercial 

End User who is not otherwise a 

Participant on AEGIS SEF to enter

into SEF Contracts on AEGIS SEF 

through a Broker Firm.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

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

Adding Definition of NPFC or NonParticipating Financial Counterparty

(1.81)

• Adding the ability for a Financial 

Counterparty who is not otherwise a 

Participant on AEGIS SEF to enter 

into SEF Contracts on AEGIS SEF 

through a Broker Firm.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Adding Definition of Offline Execution 

Functionality (1.84)

• Adds functionality to the AEGIS SEF 

Platform that will capture the details 

of trades negotiated away from the 

AEGIS SEF Platform.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Updating Definition of Participant 

Agreement (1.90)

• Adding language for the process of 

handling ECPs executing using the 

Offline Execution functionality of the 

AEGIS-SEF Platform

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Adding Definition of Permitted Offline 

Transaction (1.95)

• Adds a transaction type consisting of a 

pre-arranged or pre-negotiated swap 

transaction that can be submitted to 

AEGIS SEF for execution. 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

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

Updating Definition of SEF Contract 

(1.121)

• Clarifying that a SEF Contract can 

include a Permitted Offline 

Transaction in addition to a swap 

negotiated through the Order Book or 

RFQ Function.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Updating Definition of User ID (1.141)

• Clarifying that a User ID can also be 

used to identify a Person submitting a 

Permitted Offline Transaction

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

Updating Rule 3.2.1 - Right to access the 

AEGIS SEF Platform

• Clarifying that NPFCs and NPCEUs 

shall not be permitted to access the 

Order Book; 

• Because NPFCs and NPCEUs are not 

Participants of AEGIS SEF, they 

should not be guaranteed impartial 

access to the entire AEGIS SEF 

Platform. 

• NPFCs and NPCEUs are being added 

for the primary purpose of executing 

SEF Contracts that have been 

negotiated away from AEGIS SEF.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2 – Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.202

• § 37.9(c)(2)- Execution Methods
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Updating Rule 3.6.1 – Designation of 

Authorized Users

• Clarifying the requirement to 

designate at least one employee as an

Authorized User is only required for 

Persons accessing the AEGIS SEF 

Platform. 

• NPFCs and NPCEUs are Customers 

but they may not need to access the 

AEGIS-SEF Platform and therefore 

should not be required to designate an 

Authorized User. 

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods

Updating Rule 3.8 – Broker Firms 

Accessing the Platform

• Clarifying that Broker Firms can 

represent Customers (rather than only 

Market Participants). Customers 

include Market Participants as well as 

NPFCs and NPCEUs.

• Also clarifies that a Broker Firm can 

submit for execution a SEF Contract 

that was negotiated away from the 

SEF.

• Also includes Permitted Offline 

Transactions alongside Error Trades 

as transactions that can be prearranged trades that can be executed 

by AEGIS SEF.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods

Updating Rule 3.11.4 – Access to AEGIS 

SEF Platform

• New Persons that are not Participants 

but can execute SEF Contracts 

through the AEGIS SEF Platform 

(specifically NPFCs and NPCEUs), 

new agreements have been added.

• A standardized Broker Firm 

agreement is appropriate so that there 

is no confusion on rules, jurisdiction, 

fees, and SDR reporting obligations. 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods

• Part 43
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

• Part 45

• § 37.202(b)- Jurisdiction

Updating Rule 3.12.1-3.12.2 – Dues and 

Fees

• Clarifying that NPCEUs will be

treated the same as Market 

Participants and will not be charged 

user fees nor notional volume fees.

• Given NPFCs will not have access to 

the Order Book nor consistent RFQs, 

it is not appropriate to charge them 

User Fees; however, NPFCs will be 

subject to the same notional volume 

fees as Financial Counterparties who 

are Participants for any SEF Contracts 

posted to AEGIS SEF for execution. 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2(A)(ii)- Any 

limitation on access to the SEF

• Core Principle 13- Financial 

Resources

Updating Rule 3.14 – Liquidity Provider 

Program

• Excludes NPFCs from any LPPs.

• NPFCs are not Participants and are not 

entitled to benefits available to 

Participants. 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 2(A)(ii)- Any 

limitation on access to the SEF

Updating Rule 3.15.1 – Broker Firms

• Updates and broadens the authority of 

Broker Firms to assist Customers via 

the Offline Transaction Functionality 

(“OTF”) in addition to the Order Book 

and RFQ function.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods

Added Rule 3.15.2(f) – Broker Firms

• Created a requirement for an NPFC 

and/or NPCEU to enter into an 

agreement with a Broker Firm in order 

to have representation on AEGIS SEF. 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods

Updating Rule 4.6.3 – Permitted 

Transactions

• Added the ability for a Broker Firm to 

submit Permitted Offline Transactions 

to AEGIS-SEF for execution so long 

as that Broker Firm has entered into a 

separate agreement with the parties to 

the transaction. 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Updating Rule 4.6.4 – Permitted 

Transactions

• Added that a Broker Firm can execute 

a SEF Contract that has been prearranged or pre-negotiated.

• This is in addition to executing 

transactions that have been negotiated 

through the Order Book or RFQ 

Function.

• Also clarified that Permitted 

Transactions, alongside Error Trades, 

are permissible pre-arranged trades.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods

Updating Rule 4.7 – Execution Methods for 

SEF Contracts: Order Book

• Clarifying that NPFCs and NPCEUs 

shall not be permitted to access the 

Order Book; 

• Because NPFCs and NPCEUs are not 

Participants of AEGIS SEF, they 

should not be guaranteed impartial 

access to the entire AEGIS SEF 

Platform. 

• NPFCs and NPCEUs are being added 

for the primary purpose of executing 

SEF Contracts that have been 

negotiated away from AEGIS SEF.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• § 37.9(c)(2)- Execution Methods

• § 37.202 – Impartial Access

Added New Rule 4.8A – Execution 

Methods for SEF Contracts: Permitted 

Offline Transaction

• Major new rule addition detailing how 

Permitted Offline Transactions are 

submitted to AEGIS SEF for 

execution.

• Clarifies that the SEF Contract is 

considered executed at the time all 

required information regarding the 

trade is entered into the Offline 

Transaction Functionality.

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 2- Compliance with 

rules

• Core Principle 4- Monitoring of 

trading and trade processing
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

• Also creates deemed approval to a 

Broker Firm from a Financial 

Counterparty Participant to submit the 

results of a Permitted Offline 

Transaction to AEGIS SEF for 

execution - given the Financial 

Counterparty is subject to the rules, 

has an ISDA in place, and is working 

with a Broker Firm in the 

arrangement.

• Core Principle 5- Ability to obtain 

information

• Core Principle 9- Timely publication 

of trading information

• Core Principle 10- Recordkeeping and 

Reporting

• § 37.501 – Establish and enforce rules

• § 37.205(c)(1) – Annual audit trail and 

recordkeeping reviews

• § 37.6(b)- Confirmation of SEF 

Contracts

• § 37.9(c)(2)- Execution Methods

• Part 43

• Part 45

Updated Rule 4.10.4 – Confirmation of 

SEF Contracts

• Added Offline Execution 

Functionality as an execution method. 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, consistent with 

other approved SEF Rulebooks.

• Core Principle 9(B)- Transmit trade 

information

• § 37.6(b)- Confirmation of SEF 

Contracts

Updated Rule 4.15.1 – Recordkeeping; 

Audit Trail

• As previously drafted, rule referenced

using the AEGIS-SEF Platform 

electronically.

• All Users use the AEGIS-SEF 

Platform electronically.

• Clarified that 4.15.1 applies to any 

Person accessing the AEGIS-SEF 

Platform through an automated order 

system (not through an individual).

• Recordkeeping requirements for 

individuals (including for Customers) 

are included in Rule 4.15.2.

 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 10- Recordkeeping and 

reporting

• § 37.1000- Recordkeeping and 

reporting

• § 37.1001- Recordkeeping
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Updated Rule 4.15.2 – Electronic 

Communications Off-Platform

• Inclusion of Customers in rule 

pertaining to communications OffPlatform

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 2- Compliance with 

rules

• Core Principle 10- Recordkeeping and 

reporting

• § 37.1000- Recordkeeping and 

reporting

• § 37.1001- Recordkeeping

Updated Rule 4.15.4 – CTI Codes

• Clarification of CTI Code 4 for a noncustomer 

• Core Principle 2- Compliance with 

rules

• § 37.6(b) – Confirmation of SEF 

Contracts

Clarified Rule 4.18.4 – Third-Party 

Reporting Under Parts 43 and 45

• Clarified NPFC rights and obligations 

in performing Third Party Reporting

to an SDR

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 2- Compliance with 

rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• Core Principle 5- Ability to Obtain 

Information

• Core Principle 10- Recordkeeping

• Part 43

• Part 45
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Updated Rules: 2.8.1, 2.8.4, 3.1.1, 3.1.2, 

3.1.4, 3.2.1, 3.8, 3.12.1, 3.13.1, 3.13.2, 3.13.3, 

3.13.4, 4.3.3, 4.4, 4.6.2, 4.6.3, 4.6.5, 4.10.2,

4.13.1, 4.13.2, 4.15.1, 4.15.2, 4.15.3, 4.20, 

6.1. 6.1.1, 6.1.2, 6.1.3, 6.1.4, 6.1.5, 6.1.6, 6.2, 

6.2.1, 6.2.2, 6.2.12, 6.10, 6.10.1, 6.10.2, 

6.10.3, 6.11.6, 6.13, 6.13.1, 6.13.2, 6.14.3, 

7.1, 7.17, 7.18, 7.19, 8.1, 8.2, 8.3, 9.2.1, 9.2.2, 

9.2.3, 9.2.4, 9.3, 9.4, 9.7.1, 9.7.2, 9.7.3

• Clarification of information 

requirements for Broker Firm’s 

Trading Customers that are not NPFC

for KYC purposes

• Addition of the newly created 

categories “Customers” and “NPFC”s 

in multiple rules to be inclusive of all 

categories of Participants with access, 

through the Order Book, RFQ or OTF, 

to the AEGIS SEF Platform

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 2 – Compliance with 

Rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• Core Principle 5 – Ability to Obtain 

Information

• Core Principle 10 - Recordkeeping

Updated Rules 6.8.2, 6.9.3

• Inclusion of “Permitted Offline 

Transactions”, further clarifying 

reporting obligations of Customer 

Orders to the SEF

• Clarification of the types of 

prearranged or pre-negotiated 

transactions permitted on AEGIS SEF

• Clarification of the types of trades 

which may be pre-arranged off-SEF 

and then executed on-SEF

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 2 – Compliance with 

Rules

• Core Principle 4(A)- Establish rules or 

terms and conditions

• Core Principle 5 – Ability to Obtain 

Information

• Core Principle 10 – Recordkeeping

Updated Exhibit K

• Revised category from Market 

Participants to Eligible Contract 

Participants that are not Financial 

Counterparties

• Removed Monthly User Fees for 

Financial Counterparties

• Revised “Off-SEF” fees to apply to 

the Offline Execution Functionality, 

• Pre-arranged or pre-negotiated trades 

can be brought to a SEF for execution 

by an IB or a CTA, which is 

consistent with other approved SEF 

Rulebooks.

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• § 37.202 – Impartial Access
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

and made them equal to fees executed 

via the Order Book or RFQ Function

• Reduced Metals Product fees from 

$0.50/MT to $0.25/MT 

Exhibit B – AEGIS SEF Rulebook

(attached under separate cover)

Exhibit C – AEGIS SEF Fee Schedule

(attached under separate cover)

Exhibit D – AEGIS SEF Broker Firm Agreement

(attached under separate cover)

Exhibit E – AEGIS SEF Rulebook - redline

(attached under separate cover)

Exhibit F – AEGIS SEF Fee Schedule - redline

(attached under separate cover)
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Exhibit G – AEGIS SEF Broker Firm Agreement - redline

(attached under separate cover)