ICAP Global Derivatives Limited 

2 Broadgate 

London 

United Kingdom 

EC2M 7UR 

December 7, 2021 

FOIA CONFIDENTIAL TREATMENT REQUEST 

Sent via email to FOIAsubmissions@cftc.gov 

Assistant Secretary of the CFTC 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 

Dear Assistant Secretary: 

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-2021-R-9”). The IGDL Submission was submitted via the CFTC Portal. 

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

Confidential Exhibit E, and Confidential Exhibit F 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 

IGDL Inc.” and numbered as provided on Schedule A attached hereto. 

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”). 
Assistant Secretary of the CFTC for FOI, 

Privacy and Sunshine Acts Compliance 

U.S. Commodity Futures Trading Commission 

December 7, 2021 

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, 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. 

Please promptly inform Mr. Brian Donnelly, Chief Compliance Officer, ICAP Global 

Derivatives Limited at (201) 984-6956, 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. Thank you for your attention to this matter. 

Very truly yours, 

ICAP Global Derivatives Limited 

By: __________________________ 

Name: Brian D. Donnelly 

Title: Chief Compliance Officer 

Date: December 7, 2021 

Enclosure 

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

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

Privacy and Sunshine Acts Compliance 

U.S. Commodity Futures Trading Commission 

December 7, 2021 

3 

SCHEDULE A 

CONFIDENTIAL INFORMATION 

Document Subject to Request for 

Confidential Treatment Pursuant to 

§145.9 

IGDL Submission 2021-R-9 – Exhibit D 

IGDL Submission 2021-R-9 – Exhibit E

IGDL Submission 2021-R-9 – Exhibit F