made by DW SEF, during the time period covered by the report, to pursue 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) DW SEF 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 DW SEF, 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

Bh \ Def
Christopher J. Kirkpatrick
Secretary of the Commission



UNITED STATES OF AMERICA
Before the
COMMODITY FUTURES TRADING COMMISSION

In the Matter of the Application of
DW SEF LLC for
Registration as a Swap Execution Facility

ORDER OF REGISTRATION

DW SEF LLC (“DW SEF”) 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 July 5,
2013 through January 20, 2016.

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

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

(2) | DW SEF 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:

G) 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,
DW SEF shall comply with the terms and conditions of CFTC Letter No. 15-24,
for the duration set forth therein;
(ii) 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, DW SEF shall comply with the terms and conditions of
CFTC Letter No, 15-25, for the duration set forth therein;
(iii) In lieu of complying with the specific requirements of Commission
Regulation 43.2 that are addressed in CFTC Letter No, 15-60, DW SEF shall

comply with the terms and conditions of CFTC Letter No. 15-60, for the duration

set forth therein;
(iv) 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, DW SEF shall comply with the terms and conditions of CFTC Letter No. 15-
68, for the duration set forth therein; and

(vy) 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, DW
SEF 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 DW SEF, subject to and in compliance with DW SEF’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 DW SEF, 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), DW SEF shall
conduct such surveillance in accordance with the terms and conditions of the voice audit
trail surveillance program that DW SEF 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. DW SEF 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 DW SEF
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