COPY FOR PUBLIC DISCLOSURE, CONFIDENTIAL INFORMATION REMOVED 

 

Haynes and Boone, LLP

Attorneys and Counselors

800 17th Street, NW

Suite 500

Washington, D.C. 20006

T (202) 654-4500

F (202) 654-4501

www.haynesboone.com

Via Electronic Submission 

February 3, 2021 

Christopher Kirkpatrick, Secretary 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

Email: secretary@cftc.gov

Re: AEGIS-SEF, LLC, February 3, 2021 Revisions to February 2021 Revised Form SEF 

Pursuant to Section 5h of the Commodity Exchange Act and Part 37 of the 

Regulations of the Commodity Futures Trading Commission (the “Commission”) and 

Request for Freedom of Information Act Confidential Treatment 

Dear Mr. Kirkpatrick, 

On this 3rd day of February, 2021, AEGIS SEF, LLC (“AEGIS-SEF” or the 

“Applicant”) has attached hereto a downloadable encrypted zip file containing further revisions 

to (i) AEGIS-SEF’s Form SEF (including the instructions thereto), the Cover Sheet, and required 

Exhibits which AEGIS-SEF filed with the Commodity Futures Trading Commission (“CFTC” 

or the “Commission”) on December 16, 2020 (together, the “Form SEF”), filed pursuant to 

section 5h of the Commodity Exchange Act and the Commission’s regulations thereunder to 

register as a Swap Execution Facility and (ii) the materials submitted February 2, 2021 revising 

several materials contained in the December 16, 2020 Form SEF (together with the Form SEF, 

the “February 2021 Revised Form SEF”). 

Specifically, the attached zip file contains the following further revisions: 

 Exhibit U to the February 2021 Revised Form SEF, wherein AEGIS-SEF has requested 

confidential treatment of portions of the 2021 Revised Form SEF, and Appendix A to 

AEGIS-SEF’s Freedom of Information Act (“FOIA”) Confidential Treatment Request Letter 

dated December 16, 2020, have been amended to remove AEGIS-SEF’s request for 

confidentiality of Exhibits G, G-1, G-2, G-3, and G-4, all of which are documents 

establishing AEGIS-SEF’s legal status pursuant to Commission Regulation 40.8 (17 C.F.R. 

Section 40.8). AEGIS-SEF has also reattached AEGIS-SEF’s FOIA Confidential Treatment 

Request Letter dated December 16, 2020 for ease of review; and 

 AEGIS-SEF has removed the “request for confidentiality” stamps that were located at the 

bottom of each page of Exhibits G, G-1, G-2, G-3, and G-4, and has therefore included such 

amended versions of these Exhibits in the attached zip file. 
COPY FOR PUBLIC DISCLOSURE, CONFIDENTIAL INFORMATION REMOVED 

 

The revised materials contained herein are meant to supersede corresponding materials 

contained in AEGIS-SEF’s February 2021 Revised Form SEF submission. Additionally for 

Exhibit U and Appendix A to AEGIS-SEF’s FOIA Confidential Treatment Request Letter dated 

December 16, 2020, we have provided “redline” versions in the zip file which show the 

differences between the revised materials and the corresponding materials provided by AEGISSEF in its February 2021 Revised Form SEF submission. 

The password to access the files within the encrypted zip file is: . If 

you should have any issues accessing these further revisions to the February 2021 Revised Form 

SEF, please do not hesitate to contact us. 

Respectfully submitted, 

/s/Phillip Lookadoo 

Phillip G. Lookadoo 

Serge B. Agbre 

Haynes and Boone, LLP 

800 17th Street, NW, Suite 500 

Washington, DC 20006 

Telephone: 202-654-4510 

Email: phil.lookadoo@haynesboone.com 

Email: serge.agbre@haynesboone.com 

Counsel on behalf of AEGIS SEF, LLC