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Bennett Kirschner

TRADITION SEF, LLC General Counsel and Secretary

June 29, 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 40.6(a) Rulebook Amendment - Delisting of Products referenced to 

LIBOR and related changes to Tradition SEF’s Interest Rate Swap, Broad Market 

Equity Index Swap Product Listings and Tradition SEF Trad-X Platform Supplement 1. 

Tradition SEF Submission No. 2023-03 

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(a), Tradition SEF, LLC 

(“Tradition SEF” or “The SEF”) hereby notifies the Commission that it wishes to amend its Rulebook as 

provided herein and the attached Appendixes and Supplements regarding: 1) the delisting of certain 

interest rate and broad market equity index swaps; 2) revisions to its Interest Rate and Equity Swap Asset 

Class Product Listings with respect to the delisting of swaps offered for trading, and; 3) corresponding 

changes to Tradition SEF Trad-X Platform Supplement 1. 

Tradition SEF is delisting these products in accordance with the CFTC mandate to transition away from 

LIBOR to new interest rate benchmarks. USD LIBOR referenced instruments will be removed from 

Tradition systems after the market close on June 30, 2023 and will no longer be available on Tradition 

SEF execution facilities starting on trading day July 3, 2023. 

Tradition SEF is a swap execution facility. It does not own the products executed through its services or

maintain open interest as the rule contemplates open interest. Positions resulting from transactions on 

Tradition SEF are maintained by the counterparties to the transactions at Designated Clearing 

Organizations or bilaterally between the counterparties. 

Additionally, pursuant to Commission Regulation 40.6, Tradition SEF is making several non-substantive 

grammatical or formatting changes to these documents.

Redlined and final versions of Appendix A to Tradition SEF Rulebook Interest Rate Swap Product Listing, 

Appendix D Equities Product Listing and Tradition SEF Trad-X Platform Supplement 1 are attached hereto 

to reflect the changes. 
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Please note that Tradition SEF Submission No. 2023-03 includes the following revisions to the IRS 

Product Listing: 

References to LIBOR have been removed and replaced with references to SOFR or other benchmarks 

where appropriate. 

LIBOR benchmarked swaps subject to the trade execution (MAT) requirement have been removed 

LIBOR has been removed as a benchmark from Table 2. 

Please note that Tradition SEF Submission No. 2023-03 includes the following revisions to 

Appendix D Equities Product Listing: 

References to LIBOR have been removed and replaced with references to SOFR or other rate benchmarks 

where appropriate. 

Please note that Tradition SEF Submission No. 2023-03 includes the following revisions to Tradition

SEF Trad-X Platform Supplement 1:

References to LIBOR have been removed and replaced with references to SOFR where appropriate.

BUND, BOBL and SCHATZ GADGET spreads have been added to Appendix 4 – TRAD-X PRODUCTS: 

EURO INTEREST RATE SWAPS to conform to Appendix A.

GBP products referenced to LIBOR have been removed from APPENDIX 6 – TRAD-X PRODUCTS: 

STERLING INTEREST RATE SWAPS

A reference to SONIA has been added to Section 7 of APPENDIX 6 – TRAD-X PRODUCTS: 

STERLING INTEREST RATE SWAPS to conform to appendix A.

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 this pending delisting 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. 2023-02 in any related correspondence. 

Sincerely,

Bennett Kirschner

General Counsel and Secretary

Att. 

Exhibit A

Exhibit B
EXHIBITS 

A) Redline and Final version of Appendix A 

to Tradition SEF Rulebook -Interest Rate 

Swap Product Listing

B) Redline and Final version of Appendix D 

to Tradition SEF Rulebook -Equity Swap 

Product Listing

C) Redline and Final version of TRADITION SEF PLATFORM SUPPLEMENT 1