ACTIVE 247327226v.3

August 30, 2019 

FOIA CONFIDENTIAL TREATMENT REQUEST 

By overnight mail and email: FOIAsubmissions@cftc.gov

Assistant Secretary of the Commission 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. Pursuant to CFTC Regulation 37.1306 

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 amendments to 

Exhibit Q to its Form SEF pursuant to CFTC Regulation 40.6(a) (the “tpSEF Submission” or “tpSEF 

Submission 19-04R”). The tpSEF Submission was submitted via the CFTC Portal. 

tpSEF hereby requests, pursuant to CFTC Regulation 145.9, that 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 Confirmation Documents, the 

“Confidential Information”). 
Assistant Secretary of the Commission for FOI, 

 Privacy and Sunshine Acts Compliance 

U.S. Commodity Futures Trading Commission 

August 30, 2019 

2 

ACTIVE 247327226v.3

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]

Assistant Secretary of the Commission for FOI, 

 Privacy and Sunshine Acts Compliance 

U.S. Commodity Futures Trading Commission 

August 30, 2019 

4 

ACTIVE 247327226v.3

SCHEDULE A 

CONFIDENTIAL INFORMATION 

Document Subject to Request for 

Confidential Treatment Pursuant to 

§145.9 

Identifying Number and Code 

tpSEF Submission 19-04R – Exhibit A tpSEF_0032209

tpSEF Submission 19-04R – Exhibit B tpSEF_0032210 – tpSEF_0032374

tpSEF Submission 19-04R – Exhibit C tpSEF_0032375 – tpSEF_0032562