FOIA CONFIDENTIAL TREATMENT REQUEST

May 25, 2023

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, May 25, 2023, 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 May 25, 2023, changes 

were made to the following parameters: 

• bid/offer widths for CDX and iTraxx credit indices and single name risk factors

• concentration charge thresholds for index and single name risk factors

• Kendall Tau rank-order correlations for NA, EU, Asia/Pacific (“AP”), and Emerging Market (“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

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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 document which bear Bates number 

05.25.2023-000001-CFTC1 to 05.25.2023-000004-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.

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Please direct any questions or requests for information to the attention of the undersigned at Olivia.bazor@ice.com

or 904-855-5580. 

Sincerely,

Olivia Bazor

Staff Attorney