Daniel E. Glatter

General Counsel and Secretary

 TRADITION SEF, Inc. 

Tradition SEF, Inc. 32 Old Slip, 28th Floor, New York, NY 10005 F 212 791 4500 www.traditionsef.com

October 16, 2020

VIA CFTC Portal

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) Certification.

Notification of Amendments to Tradition SEF, Inc. Rulebook

Tradition SEF Submission No. 2020-05

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, Tradition SEF, Inc. 

(“Tradition SEF”) hereby notifies the Commission of amendments to its Rules 412, 539, 541 and 544 of 

the Rulebook to implement the requirements contained in Regulation 37.9(d), as described below, to be

effective for market participants on November 1, 2020. 

Tradition SEF has amended Rule 412 (Confirmations) in subsections (a) to clarify that swap 

confirmations for transactions prearranged, prenegotiated or executed anonymously in swaps made 

available to trade shall not contain counterparty identifying information. Additionally, Rule 

541(b)(1)(Counterparty Anonymity) has been amended to prohibit the disclosure of counterparty 

identifying information in MAT Transactions anonymously executed by Tradition SEF or submitted by a 

Participant, which have been prearranged or pre-negotiated anonymously on or pursuant to the rules of 

the SEF. Likewise, Rule 539 (Error Trade Policy for Tradition SEF Errors) has also been amended to 

reflect the changes necessary to give effect Rule 541 in situations when Tradition SEF resolves error 

transactions. Lastly, Rule 544 (Affirmation of Cleared Swaps) has also been revised to reflect the 

prohibitions in amended Rule 541(b)(1) for transactions submitted by Broker Firm Participants.

We have identified in Exhibit A the rule modifications and compliance with 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. A redline version of the Rulebook is attached hereto 

as Exhibit B to reflect the changes to the last version of the Rulebook. 

Tradition SEF continues to be in compliance with applicable provisions of the Act, including the Core 

Principles. In particular, Tradition SEF has determined that it is in compliance with Core Principles 1 
(Compliance with Core Principles) and 2 (Compliance with Rules), as further described in the compliance 

chart attached as Exhibit A. 

Tradition SEF hereby certifies that the rule amendments 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 rule 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/regulatory/), 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 daniel.glatter@tradition.com. Please reference Tradition SEF Submission No. 2020-

05 in any related correspondence.

Sincerely,

/s/ Daniel E. Glatter

General Counsel and Secretary

Att.:

Exhibit A

Exhibit B
EXHIBIT A

Amendments to the Rulebook

Rule Change Explanation and Analysis of the 

operation, purpose, and effect of the 

proposed rule or rule amendment 

and its compliance with applicable 

provisions of the Act, including core 

principles, and the Commission’s 

regulations thereunder.

412 Subsections (a) has been revised to clarify that swap 

confirmations for transactions prearranged, prenegotiated or 

executed anonymously in swaps made available to trade shall not 

contain counterparty identifying information

The changes to Rule 412 demonstrate 

Tradition SEF’s adherence to open 

access principles by adding provisions 

that adopt regulation 37.9(d) and that 

promote diversity of counterparties on 

the SEF. Accordingly, Tradition is 

promoting a fair, transparent platform. 

The changes to the Rule comply with 

Core Principle 2 (Compliance with 

Rules) and specifically with CFTC 

Rule 37.6, which requires that a 

confirmation of each transaction be 

issued to a counterparty as well as 

Regulation 37.202, which requires 

impartial access to the SEF and 

transparent criteria governing access 

that is applied in a fair and 

nondiscriminatory manner. By 

complying with Core Principle 2, 

Tradition SEF demonstrates its 

compliance with Core Principle 1 

(Compliance with Core Principles) 

and CFTC Regulation 37.100, which 

requires that a SEF comply with any 

requirement that the CFTC may 

impose by rule or regulation. 

539 The Rule has been revised to give effect to revisions to Rule 

541prohibiting the disclosure of counterparty identifying 

information in situations when Tradition SEF resolves error 

transactions. 

The changes to Rule 539 demonstrate 

Tradition SEF’s adherence to revised 

Regulation 37.9(d) (Methods of 

execution for required and permitted 

transactions). As such, the revised 

language is also compliant with Core 

Principle 2 (Compliance with Rules).

541 The Rule has been amended to prohibit the disclosure of 

counterparty identifying information in MAT Transactions 

anonymously executed by Tradition SEF or submitted by a 

Participant, which have been prearranged or pre-negotiated 

anonymously on or pursuant to the rules of the SEF

The changes to Rule 541 demonstrate 

Tradition SEF’s adherence to revised 

Regulation 37.9(d). Accordingly, 

Tradition is promoting a fair, 

transparent platform as required under 

Core Principle 2 (Compliance with 

Rules)
544 The Rule has been revised to reflect the prohibitions in amended 

Rule 541(b)(1) regarding the disclosure of counterparty 

identifying information for transactions submitted by Broker 

Firm Participants

The changes to Rule 544 demonstrate 

Tradition SEF’s adherence to revised 

Regulation 37.9(d). Accordingly, 

Tradition is promoting a fair and

transparent platform as required under 

Core Principle 2 (Compliance with 

Rules).
EXHIBIT B

Redlined Rulebook