February 22, 2023 

FOIA CONFIDENTIAL TREATMENT REQUEST

Sent via email to FOIAsubmissions@cftc.gov

Assistant Secretary of the CFTC for FOI,

Privacy and Sunshine Acts Compliance 

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. 

Dear Assistant Secretary: 

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 (the “tpSEF Submission” or “tpSEF 

Submission 23-02R”). The tpSEF Submission was submitted via the CFTC Portal.

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

A, Confidential Exhibit B, and Confidential Exhibit C 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”).
Assistant Secretary of the CFTC for FOI, 

 Privacy and Sunshine Acts Compliance 

U.S. Commodity Futures Trading Commission 

February 22, 2023

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.

Please promptly inform Mr. Brian Donnelly, Chief Compliance Officer, tpSEF Inc. at (201) 984-

6956, 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. Thank you for your attention to this matter. 

Very truly yours, 

tpSEF Inc.

By: __________________________

Name: Brian D. Donnelly

Title: Chief Compliance Officer 

Date: February 22, 2023

Enclosure 

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

Nancy Markowitz, CFTC (nmarkowitz@cftc.gov) 
Assistant Secretary of the CFTC for FOI, 

 Privacy and Sunshine Acts Compliance 

U.S. Commodity Futures Trading Commission 

February 22, 2023

3 

SCHEDULE A

CONFIDENTIAL INFORMATION 

Document Subject to Request for 

Confidential Treatment Pursuant to 

§145.9

tpSEF Submission 23-02R – Exhibit A 

tpSEF Submission 23-02R – Exhibit B

tpSEF Submission 23-02R – Exhibit C