1

Updated 11/29/2023

Exhibit K

AEGIS SEF, LLC

Dues, Fees, and Other Charges Imposed for SEF Services of Applicant

Attach as Exhibit K, the following:

a. A complete list of all dues, fees, and other charges imposed, or to be imposed, by or on 

behalf of the Applicant for its swap execution facility services that are provided on an exclusive 

basis and identify the service or services provided for each such due, fee, or other charges.

b. A description of the basis and methods used in determining the level and structure of the 

dues, fees, and other charges listed in paragraph (a) of this item.

c. If the Applicant differentiates, or proposes to differentiate, among its customers or classes of 

customers in the amount of any dues, fees, or other charges imposed for the same or similar 

exclusive services, describe and indicate the amount of each differential. In addition, identify 

and describe any differences in the cost of providing such services and any other factors that 

account for such differentiations.

(a) List of AEGIS-SEF Fees*

(Information shown in Section (a) of this Exhibit K will be available on the AEGIS-SEF website 

for review by Participants, Broker Firms, Customers, ISVs, and all other Persons eligible to 

become Participants, Broker Firms, Customers, or ISVs. The information shown in Sections (b) 

and (c) of this Exhibit K is confidential and proprietary and will not be available on the AEGISSEF website.)

AEGIS SEF, LLC (“AEGIS-SEF”) Master Fee Schedule:

AEGIS SEF Users Monthly User Fees Notional Volume Fee per 

Swap Executed via RFQ 

Function or Order Book

Notional Volume Fee Per 

Swap Executed via Offline 

Execution Functionality

Financial Counterparties $0 Fee from Notional Volume 

Fee Schedule; $25 minimum

per Trade

Fee from Notional Volume 

Fee Schedule; $25 

minimum per Trade

Eligible Contract 

Participants that are not 

Financial Counterparties

$0 $0 $0

Broker Firms (CTAs, IBs & 

other registered persons) 

representing Customers on 

the electronic platform

First User: $5,000 

Each Add’l User: $1,000

N/A*** N/A***

Broker Firms representing 

Customers via Offline 

Execution Functionality 

solely through API

$2,000 N/A*** N/A***

Independent Software 

Vendors (ISVs)

$5,000 N/A*** N/A***
2

*Capitalized terms used but not defined herein have the meanings given to such terms in 

the AEGIS-SEF Rulebook or the relevant agreements; In the event of any inconsistency 

between the provisions of any agreement and the provisions of the AEGIS-SEF 

Rulebook, the provisions of the AEGIS-SEF Rulebook shall prevail. All amounts 

presented are in USD.

***A Broker Firm or ISV is not a party to a SEF Contract nor is a Broker Firm or ISV a 

Participant, as defined in the AEGIS Rulebook; provided, however, a Person that is a 

Broker Firm or ISV may also become eligible to trade in its own name and for its own 

account, see Clarifying Statement #6 below.

AEGIS SEF Notional Volume Fee Schedule:

Clarifying Statements:

1. AEGIS-SEF will only charge one leg of a combination option structure.

2. No additional fees will be assessed with regards to a canceled trade or with respect to 

any action taken by AEGIS-SEF with regards to a System Error.

3. All pricing outlined in this Exhibit K is exclusive of taxes. Any sales taxes or other 

Product Notional Volume Fee 

per Swap Executed via 

RFQ Function or Order 

Book

Notional Volume Fee 

Per Swap Executed via 

Offline Execution 

Functionality

Crude Oil $0.0025 per Barrel $0.0025 per Barrel

Natural Gas $0.00025 per MMBtu $0.00025 per MMBtu

Natural Gas Liquids $0.0025 per Barrel

*Gallons to be converted to 

Barrels

$0.0025 per Barrel

*Gallons to be converted to 

Barrels

Refined Products $0.0025 per Barrel

*Gallons to be converted to 

Barrels

$0.0025 per Barrel

*Gallons to be converted to 

Barrels

Aluminum $0.25 per Metric Ton $0.25 per Metric Ton

Other Metals $0.25 per Metric Ton, Long 

Ton, Short Ton OR 

$0.000125/lb

$0.25 per Metric Ton, Long 

Ton, Short Ton OR 

$0.000125/lb

Interest Rates $10 per $1m notional $10 per $1m notional

Renewable Identification 

Numbers (RINs)

$0.0005 per RIN $0.001 per RIN

Low Carbon Fuel Standard

(LCFS)

$0.25 per LCFS $0.50 per LCFS
3

applicable taxes, excluding taxes on AEGIS-SEF’s net income, will be charged by AEGISSEF and paid by Financial Counterparties, Broker Firms, and Independent Software 

Vendors.

4. AEGIS-SEF’s currently effective fees are posted on the AEGIS-SEF website 

(https://aegis-hedging.com/swap-execution-facility/feeschedule). AEGIS-SEF may

periodically adjust its fees in accordance with Rule 3.12.4 of the AEGIS-SEF Rulebook.

5. If a Person that is a Broker Firm or ISV meets all of the eligibility requirements and

becomes eligible to trade SEF Contracts in its own name as a Participant, so that such 

Person could trade SEF Contracts in its own name and for its own account, then (i) 

whenever such Person utilizes the AEGIS-SEF Platform acting as a Broker Firm or ISV to 

trade SEF Contracts in the name of and on behalf of one or more of its Customers, it will 

incur fees on Schedule K applicable to a Broker Firm or ISV, (ii) whenever such Person 

utilizes the AEGIS-SEF Platform to trade SEF Contracts in its own name and for its own 

account, it will incur fees on Schedule K applicable to either a Financial Counterparty or an

Eligible Contract Participant that is not a Financial Counterparty, as applicable based on 

the facts and circumstances of such Person and its trades, and (iii) whenever such Person 

that is a Broker Firm or ISV utilizes the AEGIS-SEF Platform to trade SEF Contracts in its 

own name and for its own account as part of a “trading program,” as such term is defined in 

CFTC Regulations Section 4.10(g), then such Person shall be assessed a fee from the 

Notional Volume Fee Schedule and be subject to any “minimum” fee thereunder, as if such 

Person were a Financial Counterparty. Upon request by AEGIS-SEF’s CCO, a Person that 

is a Broker Firm or ISV will provide written or electronic records documenting each trade 

and evidencing its eligibility for the Fees applicable under clause (i), (ii) or (iii) of this 

Clarifying Statement #6.

Rule 3.12.1 of the AEGIS-SEF Rulebook includes the following text: “As set forth in the 

CFTC’s requirements for SEFs to provide “Impartial Access to Markets and Market 

Services,” CFTC Regulations Section 37.202(a)(3) specifies that a SEF shall apply “(3) 

Comparable fee structures for eligible contract participants and independent 

software vendors receiving comparable access to, or services from, the swap 

execution facility.” 

Additional Fees. Other than as set forth in this Exhibit K and as adjusted from time to 

time under Clarifying Statement #4, Financial Counterparties, Eligible Contract Participants that 

are not Financial Counterparties, Broker Firms, and ISVs will not be responsible for any additional 

fees, expenses, charges, or other amounts without written consent. AEGIS-SEF will comply with 

all reasonable invoicing procedures communicated by a Financial Counterparty, Eligible Contract 

Participant that is not a Financial Counterparty, Broker Firm, or ISV. Fee documentation will be 

available within the AEGIS-SEF Platform. AEGIS-SEF will submit certification of tax status of 

AEGIS-SEF upon request.

Payment. AEGIS-SEF will provide monthly invoices detailing the amount due. These 

amounts will be due and payable within 30 days of receipt of the invoice or other notice of the 

amount due. If an invoiced party fails to pay amounts in full or in part within two (2) days after the 

due date, such invoiced party agrees to pay (i) a late fee equal to five percent (5%) of the amounts

unpaid when due and (ii) interest at the Default Rate (i.e., the lesser of twelve percent (12%) per 

annum, compounded monthly, or the then maximum lawful rate), on the amounts unpaid when 

due.
4

(b) Description of the “Basis and Methods” Used to Derive the “Level and Structure” of 

the AEGIS-SEF Fees

(Information shown in Section (b) of this Exhibit K is confidential and proprietary and will not be 

available on the AEGIS-SEF website.)

The AEGIS-SEF fees set forth in Section (a) of this Exhibit K are intended to recover AEGISSEF’s day-to-day operating expenses related to staff, legal support, technology, maintaining 

platform access, ongoing technology development, market monitoring, market disruptionmanipulation mitigation, regulatory compliance-enforcement, and other administrative and 

general expenses related to AEGIS-SEF’s operations (“A&G Expenses”).

The level of such AEGIS-SEF fees has been set to allow AEGIS-SEF to recover its A&G 

Expenses in order to ensure that the AEGIS-SEF Platform is financially viable. 

The structure of such AEGIS-SEF fees, as explained in Section (c) of this Exhibit K, has been 

set to recover such A&G Expenses from the “makers” (i.e., “Financial Counterparties, acting 

as Designated Participants or otherwise”) and “Broker Firms” and “ISVs” that will be using the 

AEGIS-SEF Platform, rather than attempting to also recover an allocated portion of such A&G 

Expenses in a separate charge allocated to the “takers” (i.e., “Market Participants” or 

“NPECPs”) that will be using the AEGIS-SEF Platform. AEGIS-SEF has selected this 

differentiation of its fees among those using the AEGIS-SEF Platform in order to ensure that 

the AEGIS-SEF Platform is commercially competitive with other platforms (i.e., other financial 

resources) available to such “takers” seeking to buy or sell such uncleared bilateral swaps.
5

(c) Differentiation of Fees by User Classes Using the AEGIS-SEF Platform

(Information shown in Section (c) of this Exhibit K is confidential and proprietary and will not be 

available on the public AEGIS-SEF website.)

Makers, Takers and Broker Firms. The method for differentiation of AEGIS-SEF’s fees is 

based on the concept of “market makers” and “price takers,” which is sometimes referred to as 

the relationship between a “liquidity provider” and an “aggressor.” This approach views (i) the 

“aggressor” as a trader that removes liquidity from the market by entering orders that are 

immediately executed – hence “aggressor,” because the “aggressor” purchases SEF 

Contracts at the current at-market price for Offers or Bids, while (ii) the “liquidity provider” acts 

as a middleman willingly entering into SEF Contracts on either side of the market for a 

particular SEF Contract (i.e., willing to either buy or sell such swaps) in transactions with the 

“aggressors,” in order to make a market for the aggressors as price takers.

A “Financial Counterparty,” whether acting as a “Designated Participant” in response to an 

RFQ or posting/filling an open Order on the Order Book, is defined in the AEGIS-SEF 

Rulebook as a “liquidity provider” (i.e., a “market maker”).

Certain Financial Counterparties may choose not to participate on AEGIS-SEF and will instead 

rely on a Broker Firm to pre-arrange or pre-negotiate swap transactions. The Broker Firm may 

choose to bring these swap transactions to AEGIS-SEF for execution as a means to comply 

with CFTC Staff Letter No. 21-19. These transactions will incur the same Notional Volume fees

as any other SEF Contract executed on AEGIS SEF.

“Market Participants,” or “NPECPs” as defined in the AEGIS-SEF Rulebook, which are either 

(a) a CEU or an Eligible Affiliate of a CEU, as defined in the AEGIS-SEF Rulebook, which 

buys or sells a SEF Contract for the sole purpose of hedging its exposure to commercial risk, 

or (b) a CEU, an Eligible Affiliate of a CEU, or any other Eligible Contract Participant that buys 

or sells a SEF Contract as an investment or for speculative purposes, are “aggressors” (i.e., a 

“price taker”).

A Broker Firm, such as a CTA or an IB, may lawfully reach out to one Designated Participant

to solicit Bids/Offers for SEF Contracts on behalf of its Customers. As explained in CFTC Staff 

Letter No. 21-19, entitled “Staff Advisory on Swap Execution Facility Registration 

Requirement,” however, Broker Firms, such as CTAs, IBs and other registered persons acting 

on behalf of their Customers as Market Participants, are prohibited from reaching out 

simultaneously to multiple Designated Participants by phone, email, text message or any other 

platform to solicit uncleared bilateral swaps on behalf of their Customers, because any such 

“platform” that a Broker Firm might use must be registered with the CFTC as a SEF.

In compliance with CFTC Staff Letter No. 21-19, the AEGIS-SEF Platform provides an RFQ 

Function, as well as an Order Book, through which CTAs, IBs and other registered persons, as 

Broker Firms, and ISVs may lawfully solicit uncleared bilateral swaps for their Customers by 

reaching out simultaneously to multiple Designated Participants (i.e., “multiple Financial 

Counterparties”) to solicit Bids/Offers for SEF Contracts on behalf of their Customers that are 

Market Participants.

In this scenario, any Person acting as a Broker Firm or ISV is not a counterparty to any SEF 

Contract entered into by and between such Broker Firm’s or ISV’s Customer and any other 

Participant. Accordingly, a Broker Firm or ISV is not a “taker.”

In addition, a Broker Firm may use the Offline Execution Functionality to bring a pre-negotiated 

or pre-arranged transaction between an ECP and a Financial Counterparty to AEGIS SEF for 
6

execution.

A Broker Firm or ISV is more akin to a “market maker” than a “price taker,” but since a Broker 

Firm or ISV is not a counterparty to a SEF Contract, AEGIS-SEF has applied a separate fee to 

Broker Firms and ISVs in designating the fees to be paid by Broker Firms and ISVs as set 

forth in Section (a) of this Exhibit K. Moreover, any user access fees applied to a Broker Firm 

or ISV must: (i) cover the cost of an unknown number of Market Participants or NPECPs (i.e., 

Customers) that a Broker Firm or ISV may represent and (ii) address the cost of providing an 

acceptable solution for those CTAs, IBs and other registered persons that need to comply with 

the interpretive guidance set forth in CFTC Staff Letter No. 21-19. Note also that the fees 

applicable to a Person that is a Broker Firm or ISV when, and if, such Person is buying or 

selling SEF Contracts in its own name and for its own account, may vary as set forth in 

Clarifying Statement #6 as shown above in this Exhibit K. 

For the foregoing reasons, AEGIS-SEF has proposed differentiating its fees, as shown above 

in Section (a) of this Exhibit K, among (i) Financial Counterparties (as “Makers”), (ii) Broker 

Firms representing Customers and ISVs, and (iii) Eligible Contract Participants that are not 

Financial Counterparties (as “Takers”).