ICE NGX Canada Inc.

Suite 2610, 225 – 6

th Avenue SW

Calgary, AB

Canada T2P 1N2

ngx.com

ice.com

September 20, 2022

VIA CFTC PORTAL

Assistant Secretary of the Commission 

FOIA, Privacy and Sunshine Acts Compliance

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

Re: Freedom of Information Act Confidential Treatment Request - Amendments to the 

ICE NGX Canada Inc. (“ICE NGX”) Risk Management Framework

Dear Sir or Madam:

ICE NGX Canada Inc. (“ICE NGX”) today submitted, via the CFTC Portal, the self-certification, 

pursuant to Section 5c(c)(1) of the Commodity Exchange Act (“CEA”) and Commission Regulation 

40.6(a), of certain amendments (the “Amendments”) to the ICE NGX Risk Management 

Framework (“RMF”), with the subject line Amendment to ICE NGX Canada Inc. Rules. ICE NGX 

respectfully requests confidential treatment for the information attached to the submission as 

further described below until further notice. 

Under the Freedom of Information Act (“FOIA”), 5 USC Section 552, Section 809(g) of the DoddFrank Wall Street Reform and Consumer Protection Act and pursuant to Commission Regulation 

145.9(d)(5) and any other applicable regulations under or implementing FOIA, ICE NGX hereby 

respectfully requests that confidential treatment be maintained until further notice for the 

documents titled “Confidential Description of Amendments to ICE NGX Canada Inc. Risk 

Management Framework”. As prescribed by 17 C.F.R. 145.9(d)(4), each page of the documents 

included in this request bears the legend “Confidential Treatment Requested by ICE NGX Canada 

Inc.”

The basis for this request is that these documents contain sensitive commercial and proprietary 

information, public disclosure of which could have a material adverse effect on, and cause injury 

to, the operations and competitive position of ICE NGX and/or to its Contracting Parties. In 

addition, certain of this information could constitute material undisclosed information under 

Canadian securities laws. We request that you do not provide this information to anyone else or 

trade on this information until the information is no longer confidential. This request is not to be 

construed as a waiver of any other protection from disclosure or confidential treatment accorded 

by law, and ICE NGX will rely on and invoke any such confidentiality protection. 

ICE NGX requests that it be notified in the event the Commission intends to disclose such 

documents to any person, including to Congress or to any other governmental agency or unit 

pursuant to Section 8 of the CEA or other applicable law. ICE NGX does not waive its notification 

rights under Section 8(f) of the CEA or other applicable law with respect to any subpoena or 

summons for such documents.
 

ICE NGX Canada Inc.

Suite 2610, 225 – 6

th Avenue SW

Calgary, AB

Canada T2P 1N2

ngx.com

ice.com

In accordance with the foregoing regulations, kindly notify me (403-974-1740 or 

martin.mcgregor@ice.com) or Greg Abbott, ICE NGX President & COO (403-974-1701 or 

greg.abbott@ice.com) of any request under FOIA for access to such documents to enable ICE 

NGX to substantiate the grounds for confidential treatment, or if you have any questions regarding 

this document.

Yours truly,

Martin McGregor

General Counsel & CCO