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

November 3, 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(d) Notification. AEGIS SEF, LLC Weekly 

Notification of Amended Terms and Conditions

Dear Sir:

Pursuant to Section 40.6(d) 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 Exhibit N-1 Participant Agreement. The amended 

Exhibit N-1 shall become effective November 3, 2022.

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 Exhibit N-1 Participant Agreement is attached under separate cover as 

Exhibit B. A redlined version of the Exhibit N-1 Participant Agreement is attached under 

separate cover as Exhibit C. Exhibits B and C 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 B and C 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 agreement complies with the Act and the

Commission’s regulations thereunder, and (ii) copy of this submission is being

concurrently posted on AEGIS’s website. There were no substantive opposing views to the

amendments to Exhibit N-1.

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

questions regarding this matter.

Andrew Furman

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

AEGIS SEF, LLC

2829 Technology Forest Blvd

Suite 260

The Woodlands, TX 77381

Exhibit A – Explanation 

Amendment and Explanation Supporting Rule / Core Principle

Clarifying reporting requirements for 

Participants who are Financial 

Counterparties

• Separating reporting requirements by 

which SDR is being reported to 

• 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

• Core Principle 5 – Ability to Obtain 

Information

• Core Principle 10 – Recordkeeping

• Part 43

• Part 45

Updating references of ISDA

• Clarifying the types of credit 

agreements which are acceptable by 

replacing “ISDA” with “Mutual Credit 

Risk Mitigation Agreement”

• Core Principle 1(B)- Reasonable 

Discretion of swap execution facility

• Core Principle 4(A)- Establish rules or 

terms and conditions

• AEGIS SEF Rulebook 1.134, 4.6.5, 

4.7.5, 4.8.2, 4.10.2, 4.10.3

Amended Indemnity Provision

• Modified SEF contractual indemnity

• Core Principle 1(B)- Reasonable 

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

Incorporated Rule Updates in Excerpts 

from Rulebooks, Attachment A 

• Updated rule excerpts to coincide with 

recently certified rule amendments

• CFTC certification received 11/2/2022

for Rulebook Amendments

Incorporated Fee Schedule Updates 

• Updated Website link to Fee Schedule 

to coincide with recently certified 

amendments to Exhibit K Fees

• CFTC certification received 11/2/2022 

for Fee Schedule Amendments
AEGIS SEF | 2829 Technology Forest Boulevard, Suite 260 | The Woodlands, Texas 77381

Exhibit B – AEGIS SEF Exhibit N-1 Participant Agreement

(attached under separate cover)

Exhibit C – AEGIS SEF Exhibit N-1 Participant Agreement (redlined)

(attached under separate cover)