AEGIS SEF | 2829 Technology Forest Boulevard, Suite 440 | The Woodlands, Texas 77381

AEGIS SEF, LLC is notifying the Commodity Futures Trading Commission (“CFTC” or “Commission”) that 

pursuant to Commission Regulation 40.2(a), the Exchange is self-certifying the listing of the

Natural Gas Fixed Swap - PG&E Citygate - Platts Gas Daily

uncleared, bilateral swap contract for trading on AEGIS SEF beginning on or after September 1, 2022. 

Rulebook Chapter: 1101

The contract specifications describing the new Exchange swap contract is attached to this letter as Exhibit 

A, to be added to the AEGIS SEF Website: www.aegis-hedging.com/swap-execution-facility. The discussion 

of contracts not readily susceptible to manipulation has been segregated as Exhibit B, for which 

confidential treatment is requested. The reporting levels, accountability levels, and position limits for 

these contracts is attached to the AEGIS SEF Website. Exchange management has assessed the Exchange’s 

contracts’ compliance with applicable provisions of the Commodity Exchange Act (“Act”), including the 

Commissions Regulations thereunder and the Core Principles. 

AEGIS SEF product listings are based on contracts which have been previously certified by existing 

Designated Contract Markets (“DCM”). Each financially settled swap contract is comprised of either (a) a 

referenced price index calculated by an independent, private‐sector third party or (b) an underlying 

formula based on a DCMs futures contract. 

Regulatory compliance of AEGIS SEF’s swaps and options contracts are mostly addressed in the AEGIS SEF 

Rulebook, concisely explained as follows:

Core Principle 2 - Compliance with the Rules: Trading in the Exchange’s contracts will be subject to the 

AEGIS SEF Rulebook in Section IV, describing trading procedures, and Section VI, which establishes trading 

codes of conduct, sound trading practices, and identifies prohibited trading behavior and abuses. In 

addition, trading behavior and activity will be subject to extensive monitoring and surveillance by the 

Exchange’s Compliance Department. The Exchange’s Compliance Department has the authority to 

address disciplinary matters through investigation and enforcement procedures in accordance with 

Section VII of the Exchange Rulebook. 

Core Principle 3 - Contracts not Readily Susceptible to Manipulation: A description of the underlying cash 

markets for the Exchange’s new contracts is provided in separately attached Exhibit B, which 

demonstrates compliance that the Exchange’s new contracts are not readily susceptible to manipulation.

In addition, the Compliance Department will review, monitor ongoing development, and conduct 

necessary amendment on the eligible products and registries in accordance with the applicable CFTC 

Regulations.

Core Principle 4 - Prevention of Market Disruption: Trading in the Exchange’s contracts will be subject to 

the AEGIS SEF Rulebook Section VI, which prohibits disruptive trading behavior and manipulation, subject 

to monitoring and surveillance by the Exchange’s Compliance Department. 

Core Principle 6 - Position Limitations or Accountability: To reduce the potential threat of market 

manipulation or congestion, AEGIS-SEF shall adopt for each SEF Contract, as is necessary and appropriate, 

a table containing Position Limits, position accountability levels, and reportable levels (the “Table,” on the 
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 440 | The Woodlands, Texas 77381

Exchange’s website). The Exchange monitors and enforces position accountability rules as set forth by the 

Commission for any SEF contract for which the Commission has adopted a position limit. AEGIS SEF 

anticipates that 100% of its SEF Contract will be designated as a Hedging Contract by at least one 

Participant as a Commercial End User (“CEU”) that is eligible for the End-User Exception or (ii) an Eligible 

Affiliate of a CEU that is eligible for the Hedging-Affiliate Exception. This requirement will enable such SEF 

Contract to be exempt from the CFTC’s Position Limits for speculative swap transactions under CFTC 

Regulations Part 150 and any Position Limits or accountability levels set by AEGIS-SEF for speculative swap 

transactions. 

Core Principle 7 - Availability of General Information: The Exchange will post general information, 

including the contract specifications for the new contracts, Exchange fees, and the AEGIS SEF Rulebook, 

on the Exchange’s website.

Core Principle 8 - Daily publication of Trading Information: The Exchange will publish daily information on 

settlement prices, volume, open interest and opening and closing ranges for the Exchange’s actively 

traded contracts on its website.

Core Principle 9 - Execution of Transactions: The Exchange’s new contracts will be available `on the 

Exchange’s electronic trading platform. The platform provides the market with the ability to execute the 

Exchange’s contracts via CLOB and RFQ from the interaction of multiple bids and multiple offers between 

Market Participants and Financial Counterparties which have mutual credit risk mitigation agreements in 

place.

Core Principle 10 - Trade Information: The platform will maintain all information with respect to each 

order and each consummated trade, as well as all other information relating to the trade environment. 

As such, any trade submitted to the CLOB and RFQ can be tracked from the time it is entered into the 

system until the time that it is executed, canceled or otherwise removed.

Core Principle 11 - Financial Integrity of Transactions: The Exchange will only offer and list contracts which 

are uncleared, bilateral swaps. The new contracts executed on the CLOB and RFQ will be subject to the 

Exchange Rulebook provisions as described in Section IV. All Participants on the Exchange attest to their 

status as an Eligible Contract Participant (“ECP”) in their N-1 Participant Agreement and annually per Rule 

3.4.3 of the AEGIS SEF Rulebook. All SEF Contracts settle financially between Participants bilaterally off of 

the Exchange. 

Core Principle 12 - Protection of Markets and Market Participants: Section VI of the AEGIS SEF Rulebook 

protects the market and market participants from abusive, disruptive, fraudulent, noncompetitive and 

unfair conduct and trade practices. The new contracts are subject to these rules that apply to all 

transactions in the Exchange’s contracts.

Core Principle 13 - Disciplinary Procedures: Section VII of the AEGIS SEF Rulebook describes the disciplinary 

procedures of the Exchange that authorize the Exchange to discipline, suspend, or expel anyone on the 

Exchange that violates these rules.

Core Principle 14 - Dispute Resolution: Section VIII of the AEGIS SEF Rulebook establishes rules concerning 

alternative dispute resolution, which provide for the resolution of disputes between or among Exchange 

users through the American Arbitration Association (AAA) under its Commercial Arbitration Rules. Under 

Section VIII, arbitration is available for all disputes, controversies or claims among all Exchange users 
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 440 | The Woodlands, Texas 77381

relating to Exchange activities. Pursuant to Section 5c(c) of the Act and the Commission’s Regulation 

40.2(a), the Exchange certifies that the Exchange’s new swaps and options contracts to be listed comply 

with the Act and the Commission’s Regulations thereunder. AEGIS SEF certifies that this submission has 

been concurrently posted on the AEGIS SEF website.

If you have any questions or need additional information regarding the above, please contact the 

undersigned at 832-413-5973 or sef@aegis-hedging.com or Andrew Furman, Chief Compliance Officer at 

afurman@aegis-hedging.com.

Andrew Furman

Chief Compliance Officer

AEGIS SEF, LLC

2829 Technology Forest Blvd

Suite 260

The Woodlands, TX 77381