May 13, 2015 

VIA ELECTRONIC PORTAL 

Ms. Melissa Jurgens 

Office of the Secretariat 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, DC 20581 

RE: Regulation 40.6 Rule Certification 

Modifications to Fee Schedule 

GFI Swaps Exchange LLC Submission No. 15-0003 

Dear Ms. Jurgens: 

 Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (the “Act”), 

and Section 40.6 of the regulations promulgated by the Commodity Futures Trading Commission 

(the “Commission”) thereunder, GFI Swaps Exchange LLC (the “Exchange”) hereby notifies the 

Commission that it is modifying the Exchange’s fee schedule (the “Fee Schedule”) with respect 

to transactions in credit default swaps. 

Appendix A attached hereto sets forth the addendum which modifies the Exchange’s 

most recent Fee Schedule, for which a request for confidential treatment is being simultaneously 

submitted to the Commission under separate cover. A copy of that request for confidential 

treatment is included with this submission. The Fee Schedule revisions will become effective on 

June 1, 2015. 

The Exchange’s legal department reviewed the applicable core principles as set forth in 

the Act. During the review, the Exchange identified Core Principle 2 as potentially being 

impacted by the revisions to the Fee Schedule. The Exchange determined that it is in compliance 

with Core Principle 2 in that all fees are applied to Participants on an impartial basis. 

There were no opposing views among the Exchange’s Board of Directors, members or 

market participants to the revisions. The Exchange certifies that the revisions to the Fee 

Schedule comply with the Act and the Commission’s regulations thereunder. The Exchange also 

certifies that this submission has been concurrently posted on the Exchange’s website at 

http://www.gfigroup.com
 

If you require any additional information regarding this submission, please contact me at 

(212) 968-2982. 

 Sincerely, 

 

 /s/ Daniel Glatter 

 General Counsel 

 GFI Swaps Exchange LLC 

Enclosure 
  

May 13, 2015 

FOIA CONFIDENTIAL TREATMENT REQUEST 

Pursuant to 17 C.F.R. § 145.9 

VIA ELECTRONIC PORTAL 

Assistant Secretary of the Commission for FOI, 

Privacy and Sunshine Acts Compliance 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, D.C. 20581 

 

Re: Petition for Confidential Treatment 

Dear Sir or Madam: 

GFI Swaps Exchange LLC (“GFI”) has on this date provided the material described in Appendix 

A to this letter (the “Confidential Submission”) to the Commission and staff of the Division of 

Market Oversight. 

In accordance with the provisions of Commission Regulations 145.5 and 145.9, we hereby 

request confidential treatment of the Confidential Submission. Confidential treatment is 

requested, inter alia, on the grounds that the Confidential Submission contains data and 

information which would separately disclose business transactions and trade secrets that may not 

be disclosed to third parties, as provided in Section 8(a) of the Commodity Exchange Act and 

Commission Regulation 145.5(c)(1). Confidential treatment additionally is requested on the 

grounds that the Confidential Submission is exempt from disclosure under paragraph (b)(4) of 

the Freedom of Information Act (“FOIA”) and Commission Regulations 145.5(d) and 

145.9(d)(1)(ii) because it contains commercial and financial information that is confidential and 

would be of material assistance to competitors of GFI. 

In accordance with the provisions of paragraph (d)(5) of Regulation 145.9, we request that the 

Confidential Submission be afforded confidential treatment in perpetuity. 
Assistant Secretary of the Commission for FOI, 

 Privacy and Sunshine Acts Compliance 

May 13, 2015 

Page 2 

We understand that if the Commission receives a FOIA request for the Confidential Submission, 

we will be notified of such request in accordance with the Commission’s regulations and be 

asked to submit, within ten business days, a detailed written justification for confidential 

treatment of the Confidential Submission. See Commission Regulation § 149.5(e)(1); see also 

Executive Order 12600, 52 Fed. Reg. 23781 (June 23, 1987) (detailing pre-disclosure 

notification procedures under FOIA). In such event, we request that Commission staff telephone 

or email the undersigned rather rely upon United States mail for such notice. 

If the Commission or its staff transmits any of the Confidential Submission to another federal 

agency, we request that you forward a copy of this letter to any such agency with the 

Confidential Submission and further request that you advise any such agency that GFI has 

requested that this material be accorded confidential treatment. 

The request set forth in the preceding paragraphs also apply to any memoranda, notes, transcripts 

or other writings of any sort whatsoever that are made by, or at the request of, any employee of 

the Commission (or any other federal agency) and which (1) incorporate, include or relate to any 

aspect of the Confidential Submission; or (2) refer to any conference, meeting, or telephone 

conversation between GFI, its current or former employees, representatives, agents, auditors or 

counsel on the one hand and employees of the Commission (or any other government agency) on 

the other, relating to the Confidential Submission. 

Any questions regarding this request for the Confidential Treatment, as well as any notices 

pursuant to Commission Regulation § 145.9(e), should be directed to the attention of the 

undersigned at the addresses and telephone number provided herein. 

**** 

Should you have any questions, or receive any requests for copies of the enclosed, please contact 

the undersigned at (212) 968-2982 or daniel.glatter@gfigroup.com. 

 Very truly yours, 

 /s/ Daniel Glatter 

 General Counsel 

 GFI Swaps Exchange LLC 

Enclosure 
APPENDIX A 

to May 13, 2015 Confidential Treatment Request 

Submitted on Behalf of 

GFI Swaps Exchange LLC 

The Confidential Submission referenced in the letter to which this Appendix A is attached 

consists of this Appendix A in addition to the following document, submitted to the Division of 

Market Oversight via submissions@cftc.gov: 

 A document titled “Addendum A to GFI Swaps Exchange LLC Fee Schedule”.