February 4, 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 

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 Pursuant to Section 5c(c) of the CEA and Part 40.6(a) of the 

Regulations of the CFTC by tpSEF Inc. 

Dear Sir or Madam: 

tpSEF Inc. (“tpSEF”), a swap execution facility registered with the Commodity Futures Trading 

Commission (the “CFTC” or “Commission”), today submitted to the Secretary of the Commission an 

amendment to its fee schedule (the “tpSEF Submission” or “tpSEF Submission 20-01F”) pursuant to 

Section 5c(c) of the Commodity Exchange Act, as amended, and Section 40.6(a) of the CFTC’s 

regulations. tpSEF submitted the tpSEF Submission, including the related exhibits, via the CFTC Portal. 

tpSEF hereby requests, pursuant to CFTC Regulation 145.9, that Exhibits A, B and C to the tpSEF 

Submission (the “Confidential Documents”) be accorded confidential treatment on the grounds that 

disclosure would reveal, at a minimum, 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 labelled “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”). 

ACTIVE 253796262 
Assistant Secretary of the Commission for FOI, 

 Privacy and Sunshine Acts Compliance 

Commodity Futures Trading Commission 

February 4, 2020 

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. 

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, NJ 07302, 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 

Commodity Futures Trading Commission 

February 4, 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, 

tpSEF Inc. 

By: _______________________ 

Name: Brian D. Donnelly 

Title: Chief Compliance Officer 

Date: February 4, 2020 

Enclosures 

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

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

 Privacy and Sunshine Acts Compliance 

Commodity Futures Trading Commission 

February 4, 2020 

SCHEDULE A 

CONFIDENTIAL INFORMATION 

Document Subject to Request for 

Confidential Treatment Pursuant to 

§145.9 

Identifying Number and Code 

tpSEF Submission 20-01F – Exhibit A tpSEF_0033673

tpSEF Submission 20-01F – Exhibit B tpSEF_0033674 – tpSEF_0033692 

tpSEF Submission 20-01F – Exhibit C tpSEF_0033693 – tpSEF_0033713