COPY FOR PUBLIC DISCLOSURE, CONFIDENTIAL INFORMATION REMOVED 

 

Haynes and Boone, LLP

Attorneys and Counselors

800 17th Street, NW

Suite 500

Washington, D.C. 20006

T (202) 654-4500

F (202) 654-4501

www.haynesboone.com

Via Electronic Submission 

February 2, 2021 

Christopher Kirkpatrick, Secretary 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

Email: secretary@cftc.gov

Re: AEGIS-SEF, LLC, February 2, 2021 Revisions to December 16, 2020 Application for 

Registration as a Swap Execution Facility Pursuant to Section 5h of the Commodity 

Exchange Act and Part 37 of the Regulations of the Commodity Futures Trading 

Commission (the “Commission”) and Request for Freedom of Information Act 

Confidential Treatment 

Dear Mr. Kirkpatrick, 

On this 2nd day of February, 2021, AEGIS SEF, LLC (“AEGIS-SEF” or the 

“Applicant”) has attached hereto a downloadable encrypted zip file containing several revisions 

to the Form SEF (including the instructions thereto), the Cover Sheet, and required Exhibits 

which AEGIS-SEF filed on December 16, 2020 (together, “Form SEF”), pursuant to section 5h 

of the Commodity Exchange Act and the Commission’s regulations thereunder to register as a 

Swap Execution Facility (together with the revised documents contained herein, the “February 

2021 Revised Form SEF”). Please note that AEGIS-SEF has requested confidential treatment of 

portions of the 2021 Revised Form SEF which is detailed in Exhibit U to the Form SEF. 

The following revised materials contained herein are meant to supersede corresponding 

materials contained in AEGIS-SEF’s December 16, 2020 submission. For all such materials, 

except Exhibits D-1 and O, we have provided “redline” versions of the materials which show the 

differences between the revised materials and the corresponding materials originally provided by 

AEGIS-SEF in its December 16, 2020 Form SEF. We note that the materials contain a new 

Exhibit O, which is AEGIS-SEF’s Compliance Manual and entirely replaces the Exhibit O that 

was included in AEGIS-SEF’s December 16, 2020 Form SEF submission. The revised materials 

consist of the following: 

 AEGIS-SEF, SEF Application Table of Contents (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit B (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit D-1 (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit E (Revised 2-2-2021); 
COPY FOR PUBLIC DISCLOSURE, CONFIDENTIAL INFORMATION REMOVED 

 

 AEGIS-SEF, SEF Application Exhibit F (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit K (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit L (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit M-1 (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit O (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit P (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit Q (Revised 2-2-2021); 

 AEGIS-SEF, SEF Application Exhibit U (Revised 2-2-2021); 

 Appendix A to FOIA Confidential Treatment Request (Revised 2-2-2021); and 

 AEGIS-SEF, SEF Application Exhibit V (Revised 2-1-2021) 

As noted above, the zip file contained herein is encrypted due to AEGIS-SEF’s request 

for confidential treatment included as Exhibit U to the February 2021 Revised Form SEF. The 

password to access the files within the encrypted zip file is: . If you should 

have any issues accessing the February 2021 Revised Form SEF, please do not hesitate to contact 

us. 

Respectfully submitted, 

/s/Phillip Lookadoo 

Phillip G. Lookadoo 

Serge B. Agbre 

Haynes and Boone, LLP 

800 17th Street, NW, Suite 500 

Washington, DC 20006 

Telephone: 202-654-4510 

Email: phil.lookadoo@haynesboone.com 

Email: serge.agbre@haynesboone.com 

Counsel on behalf of AEGIS SEF, LLC