Assistant Secretary of the Commission for FOI,

Privacy and Sunshine Acts Compliance
Commodity Futures Trading Commission
December 13, 2019

SCHEDULE A
CONFIDENTIAL INFORMATION

tpSEF Submission 19-02F — Exhibit A

tpSEF_0033307

tpSEF Submission 19-02F — Exhibit B

tpSEF_0033308 ~ tpSEF_0033328

tpSEF Submission 19-02F - Exhibit C

tpSEF_0033329 — tpSEF_0033349



() tullett prebon

tpSEF Inc,
101 Hudson Street
Jersey City

NJ 07302

USA

tel +1201 557 5000
fax +1201 557 5995

web wwwtullettprebon.com

December 13, 2019

FOIA CONFIDENTIAL TREATMENT REQUEST

By overnight mail and email: FOIAsubmissions@cftc.gov

Assistant Secretary of the Commission for FOI,
Privacy and Sunshine Acts Compliance

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Freedom of Information Act (“FOJA”) Confidential Treatment Re: for Information
Submitted to the CFTC Pursuant to Section 5c(c) of the CEA and Part 40.6(a) of the
Regulations of the CFTC by tpSEF Inc.

Dear Sir or Madam:

tpSEF Inc. (“tpSEF”), a swap execution facility registered with the Commodity Futures Trading
Commission (the “CFTC” or “Commission”), today submitted to the Secretary of the Commission an
amendment to its fee schedule (the “tpSEF Submission” or “tpSEF mission 19-02F”) pursuant to
Section Sce(c) of the Commodity Exchange Act, as amended, and Section 40.6(a) of the CFTC’s
regulations. tpSEF submitted the tpSEF Submission, including the related exhibits, via the CFTC Portal.

tpSEF hereby requests, pursuant to CFTC Regulation 145.9, that Exhibits A, B and C to the tpSEF
Submission (the “Confidential Documents”) be accorded confidential treatment on the grounds that
disclosure would reveal, at a minimum, 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 labelled “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 Confidential Documents, the
“Confidential Information”).

ACTIVE 252071950


Assistant Secretary of the Commission for FOI,

Privacy and Sunshine Acts Compliance
Commodity Futures Trading Commission
December 13, 2019

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.

In addition, please note the accompanying request that your Office acknowledge receipt of the request for
confidential treatment, by date-stamping and returning one copy of the enclosed cover letter, in the
enclosed self-addressed, postage-prepaid envelope.

Please promptly inform Mr. Brian Donnelly, Chief Compliance Officer, tpSEF Inc. at 101 Hudson Street,
Jersey City, NJ 07302, 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
Commodity Futures Trading Commission
December 13, 2019

Thank you for your attention to this matter. Please contact the undersigned at (201) 984-6956 or by email
at bddonnelly@tullettprebon.com with any questions.

Very truly yours,

tpSEF Inc.

Name: Brian D. Donnelly
Title: Chief Compliance Officer

Date: December 13, 2019
Enclosures

cc: CFTC Division of Market Oversight (dmosubmissions@cftc.gov)
Nancy Markowitz, CFTC (nmarkowitz@cftc.gov)