I Tradition |

TRADITION SEF, Inc. Senior Regulatory Counsel and Secretary
Legal Department

December 11, 2015

VIA E-MAIL (submissions@cfte.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) Certification. Request for Product Certification of Tradition
SEF’s Interest Rate Swap Asset Class Product Listing.
Tradition SEF Submission No. 2015-14,

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 revisions to its Interest Rate Swap Asset Class
Product Listing Terms and Conditions (the “IRS Product Listing Terms and Conditions”) for Brazilian
CDI Swaps offered for trading on Tradition SEF. The attached revised IRS Product Listing Terms and
Conditions supersedes and replaces the IRS Product Listing Terms and Conditions contained in CFTC
Submission No. 2015-09, filed on July 8, 2015. The expected listing date for the revisions contained
herein is December 30, 2015.

A Brazilian CDI Swap is a swap where the floating rate is calculated using an average rate and has only
one payment, which occurs at maturity. The average rate used for the Floating Leg is the Average One-
Day Interbank Deposit (aka the CDI rate, or overnight DI rate) which is an annual rate and is calculated
daily by the Central of Custody and Financial Settlement of Securities, Brazil, (CETIP). It represents the
average rate of all inter-bank overnight transactions in Brazil.

A redlined version of IRS Product Listing Terms and Conditions is attached hereto as Exhibit A, which
reflects the changes to CFTC Submission No. 2015-09. Tradition SEF Submission No. 2015-14 includes
the following revisions to the IRS Product Listing and Terms and Conditions:

Appendix A, “General Specifications”:
¢ Brazilian CDI Swaps were added to Table 2 of the Product List in Section 5.
Appendix B, “Product Specifications and Terms and Conditions”:

¢ Brazilian CDI Swaps were added to Section M to provide product specifications.

Tradition SEF, Inc. 255 Greenwich Street, 4" floor, New York, NY 10007 F 2127914500  www.traditionsef.com


Tradition SEF hereby certifies its continued compliance with applicable provisions of the Act, including
the SEF core principles (“Core Principles”) as set forth in Section Sh of the Act and Part 37 of the
Commission’s regulations promulgated thereunder. In particular, the products listed in this submission
adhere to Core Principles 3 (“Swaps Not Readily Susceptible to Manipulation”) and 7 (“Financial
Integrity of Transactions”) and CFTC Regulations 37.300-301 and 700-702. Tradition SEF herein
demonstrates that the contracts listed for trading on Tradition SEF are not readily susceptible to
manipulation.

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 pending certification with the Commission
and a copy of the submission on its website (see http:/Avww.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 scot.halvorsen@tradition.com. Please reference Tradition SEF Submission No. 2015-14
in any related correspondence.

Sincerely,

AIPA

Scot J. Halvorsen
Senior Regulatory Counsel and Secretary

Attachments:

Exhibit A


EXHIBIT A

Interest Rate Swap Asset Class Product Listing Terms and Conditions

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