Bennett Kirschner

TRADITION SEF, LLC General Counsel and Secretary

November 4, 2022 

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) Rule Certification.

Notification of Amendments to StreamGlobal Credit Default Swap Trading 

Platform Supplement. 

Tradition SEF Submission No. 2022-07. 

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(a), 

Tradition SEF, Inc. (“Tradition SEF”) hereby notifies the Commission of amendments to the

StreamGlobal Credit Default Swap Trading Platform Supplement to the Tradition SEF Rulebook 

(the “Platform Supplement”), to be effective and implemented by Tradition SEF as of November 

21, 2022. Attached as Exhibit B is a redlined version of the Platform Supplement reflecting the 

amendments described herein.

We have identified on Exhibit A the updated Platform Supplement which makes amendments to 

Rule S3-104(b)(iii) and adds Appendix 3 to the Platform Supplement, in compliance with the 

SEF core principles (the “Core Principles”) as set forth in Section 5h of the Act and Part 37 of the 

Commission’s regulations promulgated thereunder. 

Tradition SEF continues to comply with the Core Principles. In particular, Tradition SEF has 

determined that it is in compliance with Core Principle 1 (Compliance with Core Principles) and 

Core Principle 2 (Compliance with Rules), as further described in the compliance table provided 

in Exhibit A. 

Tradition SEF hereby certifies that the rule amendments comply with the 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. 

Tradition SEF, LLC 32 Old Slip, 28th floor, New York, NY 10005 212-791-4500 www.traditionsef.com
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Should you require additional information related to this submission, please contact the 

undersigned at 212-377-2337 or bennett.kirschner@tradition.com. Please reference Tradition

SEF Submission No. 2022-07 in any related correspondence.

Sincerely,

/s/ Bennett Kirschner

General Counsel and Secretary

Attachments: Exhibit A – Compliance with Core Principles table 

Exhibit B – Platform Supplement (redline format)
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EXHIBIT A 

Compliance with Core Principles

Rules 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.

Platform 

Supplement 

Rule S3-

104(b)(iii) 

and 

Appendix 3

Tradition SEF amended the Platform 

Supplement Rule S3-104(b)(iii) to update 

the work-up timing to conform with market 

practice and to add Appendix 3 to the 

Platform Supplement to add a new feature to 

the system, “Ad Hoc Mid-Price Match”. 

The purpose of this amendment to Rule S3-

104(b)(iii) is to update the timing of the 

public phase of a work-up to 60 seconds to 

conform with market practice, and to add

Appendix 3 to the Platform Supplement to

add a new feature to the system, “Ad Hoc 

Mid-Price Match”, to enable Participants to 

source liquidity on a specific instrument 

versus “Continuous Mid-Price Match” that 

sources liquidity across all instruments.

These changes are made to reflect changing 

market conditions. 

Tradition SEF continues to comply with 

Core Principles 2 (Compliance with rules) 

and 4 (Monitoring of trading and trade 

processing) and CFTC Regulation 37.200(c), 

which requires a SEF to “[e]stablish rules 

governing the operation of the facility, 

including rules specifying trading

procedures to be used in entering and 

executing orders traded or posted on the 

facility, including block trades.”
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EXHIBIT B 

Redlined StreamGlobal Credit Default Swap Trading Platform Supplement 3 version 2.4 to version 2.5

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