1

Confidential Treatment Requested by TW SEF LLC Pursuant to 17 CFR Part 154

September 18, 2020

Via email to FOIAsubmissions@cftc.gov

Assistant Secretary of the Commission for FOIA

Privacy and Sunshine Acts Compliance

U.S. Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Re: FOIA Confidential Treatment Request of Appendices A to C

Dear Assistant Secretary:

TW SEF LLC (“TW SEF”) hereby requests that the U.S. Commodity Futures Trading 

Commission (the “Commission”) accord confidential treatment under the Freedom of 

Information Act (the “FOIA”) to the attached appendices (“Appendices A to C”) which were 

submitted to the Commission on this date. This request pertains to all material in 

Appendices A to C, and additional redacted versions of Appendices A to C are included 

with this submission. TW SEF requests that confidential treatment be afforded as long 

as the Commission retains Appendices A to C. In accordance with the Commission’s 

FOIA regulations, Appendices A to C A bear the designation “Confidential Treatment 

Requested by TW SEF LLC.”

This request for confidential treatment under the FOIA is made pursuant to Commission 

Regulations 40.8 and 145.9(d), as Appendices A to C contain information that would 

reveal the trade secrets or confidential commercial or financial information of TW SEF 

and its affiliates. As required by Commission Regulation 40.8(c)(1), TW SEF has 

submitted, together with this request, a detailed written justification in support of the

confidentiality of Appendices A to C.

This request shall not be construed as a waiver of any protection from disclosure or 

confidential treatment under Commission Regulations or any other protection from 

disclosure or confidential treatment accorded by law, and TW SEF will rely on and invoke 

any such confidentiality protection with respect to Appendices A to C. TW SEF requests 

that the Commission advise the undersigned, its representative, in advance of any 

disclosure of Appendices A to C pursuant to the FOIA so that this request for confidential 

treatment may be further substantiated. TW SEF further requests that if any of the 

Confidential Information is to be disclosed to Congress or any other federal or state 

governmental agency or department, a request for confidential treatment be made by the 

Commission on TW SEF’s behalf, or that we be permitted to make such a request directly.

If you have any questions, please do not hesitate to contact the undersigned at 646-560-

7223 or by email at Gregory.Compa@tradeweb.com.
2

CONFIDENTIAL TREATMENT REQUESTED BY TW SEF LLC PURSUANT TO 17 CFR PART 145

Very truly yours,

Gregory Compa

Chief Compliance Officer

TW SEF LLC
3

CONFIDENTIAL TREATMENT REQUESTED BY TW SEF LLC PURSUANT TO 17 CFR PART 145

APPENDIX A

Fully Integrated API Services Fee Schedule (GBP Swaps)

(Blackline and Clean Copies)

[REDACTED]
4

CONFIDENTIAL TREATMENT REQUESTED BY TW SEF LLC PURSUANT TO 17 CFR PART 145

APPENDIX B 

Fully Integrated API Services Fee Schedule (EMEA Swaps)

(Blackline and Clean Versions)

[REDACTED]
5

CONFIDENTIAL TREATMENT REQUESTED BY TW SEF LLC PURSUANT TO 17 CFR PART 145

APPENDIX C 

Fully Integrated API Services Fee Schedule (Regional Rate Swaps Currencies)

(Blackline and Clean Versions)

[REDACTED]