Maria Alarcon

Manager, Legal

FOIA CONFIDENTIAL TREATMENT REQUEST

September 16, 2022

VIA ELECTRONIC PORTAL

Assistant Secretary of the CFTC

for FOIA, Privacy and Sunshine Acts Compliance 

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: Weekly Notification of Rule Amendments – Updates to Risk Parameters Established by ICC 

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act and Commission Regulation 

40.6(d)

Dear Assistant Secretary:

In conjunction with the notice submitted by ICE Clear Credit LLC (“ICC”) today, September 16, 2022, to the 

Secretary of the Commodity Futures Trading Commission (“Commission”), pursuant to Section 5c(c)(1) of 

the Commodity Exchange Act and Commission Regulation 40.6(d), ICC submits the attached confidential 

documents. 

The attached documents contain updated risk parameters established by ICC in consultation with the ICC 

Risk Committee, Trading Advisory Group and/or Risk Working Group. During the week ending September

16, 2022, changes were made to the following parameters: 

• bid/offer widths for CDX and iTraxx credit indices 

• concentration charge thresholds for North American (“NA”), European (“EU”), Asia/Pacific (“AP”), 

and Emerging Market (“EM”) risk factors

• Kendall Tau rank-order correlations for NA, EU, AP, and EM risk factors

• MAD estimates (inclusive of EWMA) for NA, EU, AP, and EM risk factors

• left and right tail parameters for NA, EU, AP, and EM risk factors

• recovery rates for NA risk factors

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Under the Freedom of Information Act (“FOIA”), 5 USC Section 552, Section 809(g) of the Dodd-Frank Wall 

Street Reform and Consumer Protection Act and pursuant to Commission Regulation 145.9(d), Federal 

Reserve Board Regulation 261.15 and any other applicable regulations under or implementing FOIA, ICE 

Clear Credit hereby respectfully requests that confidential treatment be maintained for the documents which 

bear Bates numbers 09.16.2022-000001-CFTC1 to 09.16.2022-000005-CFTC1 until further notice. In 

accordance with Commission Regulation 145.9(d)(4), every page of the confidential information bears the 

designation “Confidential Treatment Requested by ICE Clear Credit LLC.” 

ICE Clear Credit also requests that the Commission or the Board notify the undersigned immediately after 

receiving any FOIA request for such documents or any other court order, subpoena or summons for the 

same. Finally, ICE Clear Credit requests that it be notified in the event the Commission or the Board intends 

to disclose such documents to Congress or to any other governmental agency or unit pursuant to Section 8 
of the Commodity Exchange Act, as amended (“CEA”) or other applicable law. ICE Clear Credit 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 document(s).

The basis for the request is that disclosure of these document(s) would reveal confidential commercial and 

financial information of ICE Clear Credit, the disclosure of which could have a material adverse effect on, 

and cause injury to, the operations and competitive position of ICE Clear Credit. This request is not to be 

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

and ICE Clear Credit will rely on and invoke any such confidentiality protection.

***********************

Please direct any questions or requests for information to the attention of the undersigned at 

maria.alarcon@ice.com or (312) 836-6854.

Sincerely,

Maria Alarcon

Manager, Legal

ICE Clear Credit LLC

353 North Clark Street, Suite 3100

Chicago, IL 60654