April 29, 2020

FOIA CONFIDENTIAL TREATMENT REQUEST

By email: FOIAsubmissions@cftc.gov

CFTC FOIA Compliance Office

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Freedom of Information Act (“FOIA”) Confidential Treatment Request for Information 

Submitted to the CFTC by tpSEF Inc. Pursuant to CFTC Regulation 40.6(a)

Dear Sir or Madam:

tpSEF Inc. (“tpSEF”), a swap execution facility registered with the Commodity Futures Trading 

Commission (“CFTC”), today submitted to the CFTC’s Division of Market Oversight a rule certification 

pursuant to CFTC Regulation 40.6(a) (the “tpSEF Submission”). The tpSEF Submission was submitted 

via the CFTC Portal.

tpSEF hereby requests, pursuant to CFTC Regulation 145.9, that Confidential Exhibit D, Confidential 

Exhibit E and Confidential Exhibit F of the tpSEF Submission (the “Confidential Documents”) be

accorded confidential treatment on the grounds that disclosure would reveal confidential commercial and 

financial information and would be of material assistance to competitors of tpSEF. Our specification of 

these grounds for confidential treatment shall not preclude us from identifying additional grounds for 

confidential treatment at a later time. Each page of the Confidential Documents has been labeled

“Confidential Treatment Requested by tpSEF Inc.” and numbered as provided on Schedule A attached 

hereto.

Additionally, tpSEF requests FOIA confidential treatment of any notes, memoranda or other records 

created by or at the direction of the CFTC, its officers or staff members, that reflect, refer or relate to the 

Confidential Documents (the “Confidential Records”, and together with the Confidential Documents, the 

“Confidential Information”).
CFTC FOIA Compliance Office

U.S. Commodity Futures Trading Commission

April 29, 2020

2

This request for FOIA confidential treatment is sought for as long as the CFTC remains in control and/or 

possession of any Confidential Information.

We request that if the CFTC receives a FOIA request for any Confidential Information, tpSEF will be 

notified of such request in accordance with the CFTC’s regulations and have the opportunity to submit a 

written justification for confidential treatment of the Confidential Information.

In the event the CFTC or its staff provides any of the Confidential Information to another federal agency, 

we request that the CFTC provide a copy of this letter to such agency with the Confidential Information 

and further request that the CFTC or its staff inform such agency that tpSEF has requested that this 

material be accorded confidential treatment.

In addition, please note the accompanying request that your Office acknowledge receipt of the request for 

confidential treatment, by date-stamping and returning one copy of the enclosed cover letter, in the 

enclosed self-addressed, postage-prepaid envelope.

Please promptly inform Mr. Brian Donnelly, Chief Compliance Officer, tpSEF Inc. at 101 Hudson Street, 

Jersey City, New Jersey 07302, or by email at bddonnelly@tullettprebon.com, of any request under FOIA 

seeking access to the Confidential Information to enable tpSEF to further substantiate the grounds for 

confidential treatment.

[Remainder of this page intentionally blank]
CFTC FOIA Compliance Office

U.S. Commodity Futures Trading Commission

April 29, 2020

3

Thank you for your attention to this matter. Please contact the undersigned at (201) 984-6956 or by email 

at bddonnelly@tullettprebon.com with any questions.

Very truly yours,

tpSEF Inc.

By: _______________________

Name: Brian D. Donnelly

Title: Chief Compliance Officer

Date: April 29, 2020

Enclosures 

cc: CFTC Division of Market Oversight (Email: dmosubmissions@cftc.gov)

Nancy Markowitz, CFTC (Email: nmarkowitz@cftc.gov)
CFTC FOIA Compliance Office

U.S. Commodity Futures Trading Commission

April 29, 2020

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SCHEDULE A

CONFIDENTIAL INFORMATION

Document Subject to Request for 

Confidential Treatment Pursuant to 

§145.9

Identifying Number and Code

Confidential Exhibit D tpSEF_0038075–tpSEF_0038078

Confidential Exhibit E tpSEF_0038079–tpSEF_0038144

Confidential Exhibit F tpSEF_0038145–tpSEF_0038227

ACTIVE 256595074