Katten

KattenMuchinRosenman tte

525 W. Monroe Street
Chicago, IL 60661-3693
312.902.5200 tel

www. kattenlaw.com

Ross PAzzot
ross.pazzol@kattenlaw.com
312.902.5554 direct
312.902.1061 fax

August 25, 2015

FOIA CONFIDENTIAL TREATMENT REQUEST
Pursuant to 17 C.F.R. §§ 145.5 and 145.9

BY ELECTRONIC MAIL (FOIAsubmissions@cfte.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: Petition for Confidential Treatment

Dear Sir or Madam:

We have on this date provided the documents described in Appendix A to this letter (the
“Confidential Submission”) on behalf of our client GFI Swaps Exchange LLC (“GFI”) through
the Commission’s website submission portal and via email to Marilee Dahlman and Jonathan
Lave at the Division of Market Oversight.

In accordance with the provisions of Commission Regulations 145.5 and 145.9, we hereby
request confidential treatment of the Confidential Submission. Confidential treatment is
requested, infer alia, on the grounds that the Confidential Submission contains data and
information which would separately disclose business transactions and trade secrets that may not
be disclosed to third parties, as provided in Section 8(a) of the Commodity Exchange Act and
Commission Regulation 145.5(c)(1). Confidential treatment additionally is requested on the
grounds that the Confidential Submission is exempt from disclosure under paragraph (b)(4) of
the Freedom of Information Act (“FOIA”) and Commission Regulations 145.5(d) and
145.9(d)(1)(ii) because it contains commercial and financial information that is confidential and
would be of material assistance to competitors of GFI.

In accordance with the provisions of paragraph (d)(5) of Regulation 145.9, we request that the
Confidential Submission be afforded confidential treatment in perpetuity,

AUSTIN. CENTURY CITY CHARLOTTE CHICAGO HOUSTON IRVING LOS ANGELES
NEWYORK ORANGE COUNTY SANFRANCISCOBAY AREA — SHANGHAI WASHINGTON, DC
LONDON: KATTEN MUCHIN ROSENMAN UK LLP

A limited liability partnership including professional corporations
101334928



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

August 25, 2015

Page 2

We understand that if the Commission receives a FOIA request for the Confidential Submission,
we will be notified of such request in accordance with the Commission’s regulations and be
asked to submit, within ten business days, a detailed written justification for confidential
treatment of the Confidential Submission. See Commission Regulation 149.5(e)(1); see also
Executive Order 12600, 52 Fed. Reg. 23781 (June 23, 1987) (detailing pre-disclosure
notification procedures under FOIA). In such event, we request that Commission staff telephone
or email the undersigned rather than rely upon United States mail for such notice.

If the Commission or its staff transmits any of the Confidential Submission to another federal
agency, we request that you forward a copy of this letter to any such agency with the
Confidential Submission and further request that you advise any such agency that GFI has
requested that this material be accorded confidential treatment.

The requests set forth in the preceding paragraphs also apply to any memoranda, notes,
transcripts or other writings of any sort whatsoever that are made by, or at the request of, any
employee of the Commission (or any other federal agency) and which (1) incorporate, include or
relate to any aspect of the Confidential Submission; or (2) refer to any conference, meeting, or
telephone conversation between GFI, its current or former employees, representatives, agents,
auditors or counsel on the one hand and employees of the Commission (or any other government
agency) on the other, relating to the Confidential Submission.

ROR OK

Any questions regarding this request for Confidential Treatment, as well as any notices pursuant
to Commission Regulation 145.9(e), should be directed to the attention of the undersigned at the
telephone number and address set forth herein and William Shields, GFI’s Chief Compliance
Officer, at (212) 968-4122 or william.shields@gfigroup.com.

Very truly yours,

/s/

Ross Pazzol
Encl, (Appendix A)

ce: Marilee Dahlman
Jonathan Lave
Division of Market Oversight

William Shields
Daniel Glatter
GFI Swaps Exchange LLC