ICAP Global Derivatives Limited

2 Broadgate

London

United Kingdom

EC2M 7UR

March 24, 2020

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 ICAP Global Derivatives Limited Pursuant to CFTC 

Regulation 40.6 

Dear Sir or Madam:

ICAP Global Derivatives Limited (“IGDL”), 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 “IGDL Submission” or “IGDL-2020-R-1”). 

The IGDL Submission was submitted via the CFTC Portal. 

IGDL hereby requests, pursuant to CFTC Regulation 145.9, that Confidential Exhibit H, Confidential 

Exhibit I and Confidential Exhibit J of the IGDL 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 IGDL. 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 ICAP Global Derivatives Limited” and numbered as provided on 

Schedule A attached hereto.

ACTIVE 255620711 
Assistant Secretary of the Commission for FOI,

 Privacy and Sunshine Acts Compliance

U.S. Commodity Futures Trading Commission

March 24, 2020

2

Additionally, IGDL 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”).

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, IGDL 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 IGDL 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, ICAP Global Derivatives 

Limited 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 IGDL 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

March 24, 2020

3

Thank you for your attention to this matter. Please contact the undersigned at (201) 984-6956 or by email 

at bddonnelly@tullettprebon.com with any questions.

Very truly yours,

ICAP Global Derivatives Limited

By: _______________________

Name: Brian D. Donnelly

Title: Chief Compliance Officer

Date: March 24, 2020

Enclosures 

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

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

 Privacy and Sunshine Acts Compliance

U.S. Commodity Futures Trading Commission 

March 24, 2020 

4 

SCHEDULE A

CONFIDENTIAL INFORMATION

Document Subject to Request for 

Confidential Treatment Pursuant to 

§145.9

Identifying Number and Code

IGDL-2020-R-1 - Confidential Exhibit H IGDL_0001806–IGDL_0001812

IGDL-2020-R-1 - Confidential Exhibit I IGDL_0001813–IGDL_0001858

IGDL-2020-R-1 - Confidential Exhibit J IGDL_0001859–IGDL_0001927