technology that would enable the surveillance of audit trail data, for swap transactions

that are communicated or executed using voice functionality, to be conducted in

accordance with the electronic analysis capability requirements of Commission

Regulation 37.205(b)(3); and

(3) Tradition shall be responsible for compliance with the terms and conditions of this
Order of Registration, with respect to all regulatory services performed by any third party service

provider on behalf of Tradition, within or outside of the jurisdiction of the United States,
Issued in Washington, D.C, on this 22nd day of January, 2016.

By the Commission

HAG, | bh.
Christopher J. Kirkpatrick
Secretary of the Commission



UNITED STATES OF AMERICA
Before the
COMMODITY FUTURES TRADING COMMISSION

In the Matter of the Application of
Tradition SEF, Inc. for
Registration as a Swap Execution Facility

ORDER OF REGISTRATION

Tradition SEF, Inc. (“Tradition”) has submitted to the Commodity Futures Trading
Commission “Commission” or “CFTC”), pursuant to Section Sh of the Commodity Exchange
Act (“Act”), 7 U.S.C. § 7b-3, and Commission Regulation 37.3(b), 17 C.F.R. § 37,3(b), an
application for registration as a swap execution facility, which includes submissions dated
September 9, 2013 through January 20, 2016.

Having reviewed Tradition’s application, the Commission HEREBY ORDERS that,
pursuant to Section 5h of the Act and Commission Regulation 37.3(b)(6)(i), Tradition is granted
registration as a swap execution facility, subject to the terms and conditions specified herein:

(1) Tradition shall comply with all representations and submissions made by
Tradition in support of its application for registration as a swap execution facility, as shown in
the application record;

(2) Tradition shall comply with all provisions of the Act and all requirements set
forth in the Commission’s regulations, as may be amended or adopted from time to time, that are

applicable to swap execution facilities, provided that:



(a) As prior relief granted by Commission staff pursuant to Commission Regulation

140,99 remains in effect:

i

ii.

iii,

iv.

In lieu of complying with the specific requirements of Commission Regulations
37.9(a)(2) and 37.203(a) that are addressed in CFTC Letter No. 15-24, Tradition
shall comply with the terms and conditions of CFTC Letter No. 15-24, for the
duration set forth therein;

In lieu of complying with the specific requirements of Commission Regulations
37.6(b), 37.1000, 37.1001, 45.2(a) and 45.3(a) that are addressed in CFTC Letter
No. 15-25, Tradition shall comply with the terms and conditions of CFTC Letter
No, 15-25, for the duration set forth therein;

In liev of complying with the specific requirements of Commission Regulation
43.2 that are addressed in CFTC Letter No, 15-60, Tradition shall comply with the
terms and conditions of CFTC Letter No. 15-60, for the duration set forth therein;
In lieu of complying with the specific requirements of Commission Regulations
37.205(a) and 37.205(b)(2) that are addressed in CFTC Letter No. 15-68,
Tradition shall comply with the terms and conditions of CFTC Letter No, 15-68
for the duration set forth therein; and

In lieu of complying with the specific requirements of Commission Regulations
37.3(a)(2) and 37.9 that are addressed in CFTC Letter No. 15-55, Tradition shall,
for the duration set forth therein, comply with the terms and conditions of CFTC
Letter No. 15-55, and shall, in accordance with such terms and conditions,
facilitate the execution of a swap that is subject to the trade execution requirement

set forth in section 2(h)(8) of the Act, and is a component of a MAT/New



Issuance Bond Package Transaction, MAT/Futures Package Transaction,

MAT/Non-MAT Uncleared Package Transaction, MAT/Non-Swap Instruments

Package Transaction or MAT/Non-CFTC Swap Package Transaction, as each

such term is defined in CFTC Letter No. 15-55, through any method of execution

offered by Tradition, subject to and in compliance with Tradition’s rules, policies

and procedures; and

(b) When any form of voice functionality is used in the process of communicating or

executing swap transactions on or pursuant to the rules of Tradition, in lieu of conducting
surveillance of the audit trail data for such transactions in accordance with the electronic
analysis capability requirements of Commission Regulation 37.205(b)(3), Tradition shall
conduct such surveillance in accordance with the terms and conditions of the voice audit
trail surveillance program that Tradition has implemented, and has undertaken to
continue to implement, in connection with its application for registration as a swap
execution facility, as shown in the application record. Tradition shall conform such voice
audit trail surveillance program to comply with (i) any written request by Commission
staff, and (ii) any amendment to, or other modification of, the requirements of
Commission Regulation 37.205(b)(3), as they pertain to the surveillance of audit trail
data for swap transactions that are communicated or executed using voice functionality,
Subject to any such amendment to, or modification of, the requirements of Commission
Regulation 37.205(b)(3), each annual compliance report that is required to be prepared
for Tradition pursuant to Commission Regulation 37,1501(e), and submitted to the
Commission pursuant to Commission Regulation 37.1501(f), shall include a description

of the efforts made by Tradition, during the time period covered by the report, to pursue