June 18, 2020

FOIA CONFIDENTIAL TREATMENT REQUEST

By email: FOIAsubmissions@cftc.gov

Assistant Secretary of the Commission 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 tpSEF Inc. Pursuant to CFTC Regulation 

37.1306

Dear Sir or Madam:

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

Commission (“CFTC”), today submitted to the CFTC’s Division of Market Oversight amendments 

to Exhibit Q to its Form SEF pursuant to CFTC Regulation 40.6(a) (the “tpSEF Submission” or 

“tpSEF Submission 19-07R”). The tpSEF Submission was submitted via the CFTC Portal.

tpSEF hereby requests, pursuant to CFTC Regulation 145.9, that the tpSEF 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 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 labeled “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 

Confirmation Documents, the “Confidential Information”).
Assistant Secretary of the Commission for FOI,

Privacy and Sunshine Acts Compliance

U.S. Commodity Futures Trading Commission

June 18, 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. 

Please promptly inform Mr. Brian Donnelly, Chief Compliance Officer, tpSEF Inc. at 101 Hudson 

Street, Jersey City, New Jersey 07302, or by email at 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

U.S. Commodity Futures Trading Commission

June 18, 2020

3

Thank you for your attention to this matter. Please contact Brian D. Donnelly, Chief Compliance 

Officer, 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: June 18, 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

U.S. Commodity Futures Trading Commission

June 18, 2020

4

SCHEDULE A

CONFIDENTIAL INFORMATION

Document Subject to Request for 

Confidential Treatment Pursuant to 

§145.9

Identifying Number and Code

tpSEF Submission 20-08R – Exhibit A tpSEF_0038228

tpSEF Submission 20-08R – Exhibit B tpSEF_0038229 - tpSEF_0038355

tpSEF Submission 20-08R – Exhibit C tpSEF_0038356 - tpSEF_0038487