October 15, 2020

VIA ELECTRONIC MAIL (FOIAsubmissions@cftc.gov)

Assistant Secretary of the Commission for FOIA Matters

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, D.C. 20581

Re: FOIA Confidential Treatment Request: Petition Pursuant to Regulation 145.9(d)

To Whom It May Concern:

On October 15, 2020, Tassat Derivatives LLC (“Tassat”) submitted an Application for Reinstatement as a 

Swaps Execution Facility via electronic mail to Mr. Christopher J. Kirkpatrick, Secretary of the Commodity 

Futures Trading Commission. By this Petition and pursuant to Section 145.9(d) of the Commission’s 

regulations, Tassat hereby requests confidential treatment of certain information and documents described 

in the attached Appendix A (“Confidential Material”).

Pursuant to Sections 8(a) of the Commodity Exchange Act (“CEA”) and Commission Regulation 145.9(d), 

Tassat requests confidential treatment of the Confidential Material on the grounds that disclosure of such 

material would reveal trade secrets of Tassat and/or reveal Tassat’s confidential commercial information. 

The Confidential Material is proprietary to Tassat and contains highly sensitive and confidential business 

and technology information. In addition to violating Tassat’s proprietary rights, the disclosure of the 

Confidential Material would grant competitors an unfair competitive advantage and/or compromise the 

competitive advantages possessed by Tassat. Accordingly, Tassat is requesting that Mr. Kirkpatrick, staff 

members of the Division of Market Oversight and staff of any other division that may have reason to review 

any of the Confidential Material take appropriate steps to keep the Confidential Material submitted and 

provided to them confidential and to restrict the redistribution of the Confidential Material.

Pursuant to Commission Regulation 145.9(d)(5), Tassat hereby requests that the Confidential Material be 

afforded confidential treatment in perpetuity.

Tassat also requests that the Commission notify the undersigned immediately after receiving any FOIA 

request, any court order, subpoena, or summons seeking to access the Confidential Material in whole or in 

part. Tassat further requests notification through the undersigned in the event that the Commission intends 

to disclose the Confidential Material in whole or in art to Congress or to any other governmental agency or 

unit pursuant to Section 8 of the CEA. Tassat does not waive its notification under Section 8(f) of the CEA 

with respect to any subpoena or summons with respect to the Confidential Material in whole or in part.

DocuSign Envelope ID: 112F32F2-43EF-4982-AE87-62074C4B0AB8
Should you have any questions regarding the above, please contact the undersigned via phone at 312-371-

3229 or via email to ann.cresce@tassat.com.

Respectfully submitted,

Ann M. Cresce

Chief Compliance Officer

cc: Mr. Christopher J. Kirkpatrick

Attachment: Appendix 1

DocuSign Envelope ID: 112F32F2-43EF-4982-AE87-62074C4B0AB8
APPENDIX A

TASSAT DERIVATIVES LLC

Tassat Table of Contents 

Tassat Derivatives LLC FOIA Treatment Request Letter with Appendix

Tassat Derivatives LLC SEF Cover Sheet

Tassat Exhibit A – Ownership 

Tassat Exhibit B – Officer and Director Information

Tassat Exhibit C – Public Director Questionnaire

Tassat Exhibit D – Corporate Structure 

Tassat Exhibit E – Personnel Qualifications

Tassat Exhibit F – Staff Requirements and Qualifications

Tassat Exhibit H – Material Legal Proceedings

Tassat Exhibit I – Financial Information

Tassat Exhibit K1 – Tassat Market Maker Agreement

Tassat Exhibit K2 – Tassat Schedules to Market Maker Agreement

Tassat Exhibit L1 – SEF Core Principles Chart (marked version)

Tassat Exhibit N – Material Agreement Addendum 

Tassat Exhibit O1 – Market Supervision Manual (clean version)

Tassat Exhibit O2 – Market Supervision Manual (marked version)

Tassat Exhibit Q – Trading Platform

Tassat Exhibit S – Maintenance of Trading Data 

Tassat Exhibit U - Documents Subject to Request for Confidential Treatment 

Tassat Exhibit V1 – Technology Questionnaire Section 1

Tassat Exhibit V2 – Security Presentation

Tassat Exhibit V3 – Tassat Disaster Recovery Policy

Tassat Exhibit V4 – Tassat Third Party Vendor Procedures

Tassat Exhibit V5 – Tassat Vulnerability Management Procedures

DocuSign Envelope ID: 112F32F2-43EF-4982-AE87-62074C4B0AB8