Daniel E. Glatter

General Counsel and Secretary

TRADITION SEF, Inc. 

Tradition SEF, Inc. 32 Old Slip, 28th Floor, New York, NY 10005 F 212 791 4500 www.traditionsef.com

August 10, 2020

VIA CFTC PORTAL

Assistant Secretary of the Commission for FOIA,

Privacy and Sunshine Acts Compliance

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Tradition SEF, Inc. – FOIA Confidential Treatment Request

Dear Sir or Madam:

By CFTC Portal submission today, August 10, 2020, Tradition SEF, Inc. (the “Submitter”) provided the 

information attached as Exhibit A (the “Confidential Information”) and attached hereto to the Commodity 

Futures Trading Commission (the “Commission”) and staff of the Division of Market Oversight regarding 

modifications to the Tradition SEF Trad-X USD IRS Liquidity Provider Program. .

Pursuant to Commission Rules 40.8 and 145.9(d), the Submitter requests confidential treatment of the 

Confidential Information consisting of Exhibit A to this submission on the grounds that disclosure of the 

Confidential Information would reveal confidential commercial and financial information of the 

Submitter and its employees and would be considered commercially material information to competitors 

of the Submitter. 

Submitter’s notice that is reflected on Exhibit A contains information that is proprietary to the Submitter 

and forms an integral part of the competitive nature of the marketplace. Hence pending completion of its 

review and for the Submitter to continue to operate its business without undue inquiry, distraction or 

interruption, it is imperative that such information be treated as confidential. Accordingly, the Submitter 

requests confidential treatment of Exhibit A in its entirety.

Pursuant to Commission Rule 145.9(d)(5), the Submitter requests that confidential treatment of the 

Confidential Information be maintained until further notice from the Submitter. The Submitter requests 

that the Commission notify it immediately after receiving any request under the Freedom of Information 

Act (“FOIA”) or any other court order, subpoena or summons for the Confidential Information. The 

Submitter specifically notes that it does not waive, in any manner, its rights under Section 8(f) of the 

Commodity Exchange Act to receive a copy of any subpoena or summons for the Confidential 

Information prior to the Commission’s disclosure of such information pursuant to such subpoena or 

summons. Finally, the Submitter requests that the Commission notify it in the event that the Commission 

intends to disclose the Confidential Information to Congress or any federal or state governmental agency 

or department.
Assistant Secretary of the Commission for FOIA, 

Privacy and Sunshine Acts Compliance

August 10, 2020

Page 2

Should you require additional information related to this request, please contact the undersigned at (212) 

377-2337 or daniel.glatter@tradition.com.

Sincerely,

/s/ Daniel E. Glatter

General Counsel and Secretary

Att.
Assistant Secretary of the Commission for FOIA, 

Privacy and Sunshine Acts Compliance

August 10, 2020

Page 3

EXHIBIT A

Confidential Information

▪ Three page document titled “Tradition SEF Participant Notice 20-05 - Modifications to Tradition SEF -

Trad-X USD IRS Liquidity Provider Program (“LPP”)”