Message 

From: Giancarlo, Chris [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=GIANCARLO, CHRIS2A4] 

Sent: 3/15/2019 11:36:06 AM 

To: Ku I kin, Matthew [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kulkin, Matthew]; Gi ll, Michael 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gil l, Michael]; Za idi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOH F23SPDLT)/cn=Recipients/cn=azaidi]; Bussey, Brian 

[/o=CFTC/ou=Exchange Admin istrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administ ra t ive Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Sklar, Maggie 

[/o=CFTC/ou=Exchange Admin istrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Sklar, Maggieca3]; Jones, 

Shonneice [/O=CFTC/OU=Washington, DC/cn=Recipient s/cn=sknight] 

Subject: Re: Call: Chairman Giancarlo/Bakkt 

' ' 

! Non-Responsive ! i i 

L--·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-i 

On: 15 March 2019 10:52, 

"Kulkin, Matthew" <MKulkin(a),CFTC.gov> wrote: 

. ·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-} 

i Non-Responsive ! 1---·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·· 

From: Gill, Michael 

Sent: Friday, March 15, 2019 10:39 AM 

To: Zaidi, Amir; Kulkin, Matthew; Bussey, Brian; Thornton, Charlie; Sklar, Maggie; Giancarlo, Chris; Jones, Shonneice 

Subject: Re: Call: Chairman Giancarlo/Bakkt 

r·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·1 

I Non-Responsive I i·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·i 

On: 15 March 2019 10: 13, 

"Zaidi, Amir" <AZaidi@CFTC.gov> wrote: 

l. Non-Responsive. i 

From: Kulkin, Matthew 

Sent: Friday, March 15, 2019 9:56 AM 

To: Zaidi, Amir; Bussey, Brian; Thornton, Charlie; Sklar, Maggie; Giancarlo, Chris; Gill, Michael; Jones, Shonneice 

Subject: RE: Call: Chairman Giancarlo/Bakkt 

1·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·1 

i i 

I Non-Responsive I 

i.·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·i 

-----Original Appointment-----

From: Kelly Loeffler [mailto:Kelly.Loeffler@bakkt.com] 
Sent: Thursday, March 14, 2019 4:15 PM 

To: Kelly Loeffler; Zaidi, Amir; Bussey, Brian; Kulkin, Matthew; Thornton, Charlie; Sklar, Maggie; Giancarlo, Chris; Trabue 

Bland; DeWaal, Gary; 'Hahn, Arthur W.'; Gill, Michael; Jones, Shonneice 

Subject: FW: Call: Chairman Giancarlo/Bakkt 

When: Monday, March 18, 2019 4:30 PM-5:15 PM (UTC-05:00) Eastern Time (US & Canada). 

Where: Dial in below 

-----Original Appointment-----

From: Kelly Loeffler [mailto:Kelly.Loeffler@bakkt.com] 

Sent: Thursday, March 14, 2019 3:58 PM 

To: Kelly Loeffler; Giancarlo, Chris; Trabue Bland; DeWaal, Gary; 'Hahn, Arthur W.'; Gill, Michael; Jones, Shonneice 

Subject: FW: Call: Chairman Giancarlo/Bakkt 

When: Monday, March 18, 2019 4:30 PM-5:15 PM (UTC-05:00) Eastern Time (US & Canada). 

Where: Dial in below 

-----Original Appointment-----

From: Kelly Loeffler [mailto:Kelly.Loeffler@bakkt.com] 

Sent: Thursday, March 14, 2019 12:21 PM 

To: Kelly Loeffler; Trabue Bland; DeWaal, Gary; 'Hahn, Arthur W.'; Gill, Michael; Jones, Shonneice 

Subject: Call: Chairman Giancarlo/Bakkt 

When: Monday, March 18, 2019 4:30 PM-5:15 PM (UTC-05:00) Eastern Time (US & Canada). 

Where: Dial in below 

Meeting ID: 4726# 

Password: :---·(b)(4) _____ j L--·-·-·-·-·-·-·-·-·-·-·• 

External numbers 

Atlanta +1 770 618 8888 

Chicago +1 312 596 4412 

New York +1 212 896 2810 

unle::_;s ,:.:x-piic:Wv noted oth:.:ri.,,.\d::x: _ if vnu ha'-.:'i.:: rix:;Bon h> tK:lk~'-.:'i.:, are 

r=·K::>Bi:~:y:.: i·ri~{'i n::::t ;<;:_:pre::_;,:.:ni tK: ::::~1ini::::n of inierc:::::ntirn_:,nL:il E>::Jt_:u-:gi.:,, 
--·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-

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[. - -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
From: Thornton, Charlie <cthornton@CFTC.gov> 

Sent: Thursday, March 7, 2019 10:52 AM 

To: Beth Thompson <legal@fia.org> 

Cc: Maia Johnston <miohnston@fia.org> 

Subject: RE: Help! 

Non-Responsive 

From: Beth Thompson [mailto:leqal@fia.org1 

Sent: Thursday, March 7, 2019 10:50 AM 

To: Thornton, Charlie 

Cc: Maia Johnston 

Subject: RE: Help! 

Non-Responsive 

·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· ' 

From: Thornton, Charlie <cthornton@CFTC.gov> 

Sent: Thursday, March 7, 2019 10:48 AM 

To: Beth Thompson <legal@fia.org> 

Subject: RE: Help! 

l ___________________________________________________________________ N o_ n -Res po n s iv e ___________________________________________________________________ ! 

From: Thornton, Charlie 

Sent: Thursday, March 7, 2019 9:26 AM 

To: Trabue Bland; bthompson@fia.org; Thornton, Charlie 

Subject: Re: Help! 

Haha. Great thanks! Mary Beth, best number to reach you? 

On: 07 March 2019 09:22, "Trabue Bland" <Trabue.Bland@theice.com> wrote: 

Beth-. Can you help Charlie (copied). out on a Boca room issue? Charlie runs the CFTC for a bunch of 

figureheads. 

Thanks 

Trabue Bland 

Personal Assistant to Mr Charlie Thornton 
rn~~v contain ~~z>r~fak)nUt:) jnfon~·~~=::l:bn ~~nd :ntenz:j::_:d ;ut ~~•t-"-~ .. j;;~,• ,·.·v•,,-,,.,,,.,,." ~-inie~~s expjk~iUy noted c:U·~(~:t\·',/i~~e. :1 ·y~;u j·~t:\/e reason to b)lk:v\) ":/OU~~:\~ 

=-~)p:\:s~)n~ th~) ::.+,= :-:)n o! jr-:te=-~~crhn~)nttd Exz)kW\F\ 
Message 

From: Alex Albert [Alex.Albert@theice.com] 

Sent: 3/7/2019 3:14:21 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Gil I, Michael 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gil I, Michael]; Trabue Bland 

[Trabue.Bland@theice.com] 

CC: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: Inter market surveillance meeting 

So you're in a child seat listening to Murmer. Yep ..... way to make me feel old. 

From: Thornton, Charlie <cthornton(tzJCFTC.gov> 

Date: Thursday, Mar 07, 2019, 3:09 PM 

To: Alex Albert <Alex.Albert(a),theice.com>, Gill, Michael <MGill(a),CFTC.gov>, Trabue Bland <Trabue.Bland(al,tl1eice.com> 

Cc: Thornton, Charlie <cthorntonraiCFTC.g9y> 

Subject: Re: Inter market surveillance meeting 

WARNING - External email from cftc.gov 

I grew up listening to them on the way to Destin, FL as a child because they were my parents favorite band. 

On: 07 March 2019 15:05, "Alex Albert" <Alex.Albe1i@theice.com> wrote: 

Fair, but I'm old (saw them a lot in Athens, pre-fame days of '83&'84) and a big fan of 7 Chinese 

brothers. Like them all except for "shiny happy people" which is just a bizarre departure. 

From: Gill, Michael <MGill(tzJCFTC.gov> 

Date: Thursday, Mar 07, 2019, 2:55 PM 

To: Alex Albert <Alex.Albertra)theice.com>, Trabue Bland <Trabue.Bland(a)theice.com> 

Cc: Thornton, Charlie <cthomton(a),CFTC.gg_y> 

Subject: RE: Inter market surveillance meeting 

\VARNlN G - External email from cftc.gov 

Come on, i..ifos Rich Pageant is solid from beginning to end. Granted, Fables has its weak moments but I think the Don 

Gehman influence puts Pageant up there with Murmur and Reckoning (and Chronic Town for you purists on album 

counts) 

From: Alex Albert [mailto:Alex.Albert@theice.com] 

Sent: Thursday, March 7, 2019 12:24 PM 

To: Gill, Michael; Trabue Bland 

Cc: Thornton, Charlie 

Subject: RE: Inter market surveillance meeting 
Reckoning 

From: Gill, Michael <MGillC0.CFTC.gov> 

Date: Thursday, Mar 07, 2019, 12:23 PM 

To: Trabue Bland <Trabue.Bland(al.theice.com> 

Cc: Alex Albert <Alex.Albertiiz).theice.com>, Thornton, Charlie <cthornton(tzJCFTC.gov> 

Subject: RE: Inter market surveillance meeting 

\VARNING- ExternaJ email from cftc.gov 

I would object to that agenda item but would allow anything by REM pre the Green album. 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, March 7, 2019 11:55 AM 

To: Gill, Michael 

Cc: Alex Albert; Thornton, Charlie 

Subject: RE: Inter market surveillance meeting 

Sorry I didn't mean that! It was a pretty reasonable assumption that the CFTC set their agenda though. Now 

knowing this I think I will add under the CFTC agenda: Acapella rendtion of Queensryche 's seminal 1988 

album Operation Mindcrime. I look forward to Tom's version of Revolution Calling. I think it will spice up 

the meetings. 

Just joking-thanks again for following up. 

From: Gill, Michael <MGill(a).CFTC.gov> 

Date: Thursday, Mar 07, 2019, 11:41 AM 

To: Trabue Bland <Trabue.Bland(al.theice.com> 

Cc: Alex Albert <Alex.Albertra)theice.com>, Thornton, Charlie <cthornton(a)CFTC.gov> 

Subject: RE: Inter market surveillance meeting 

\VARNING- ExternaJ email from cftc.gov 

I'd prefor to not get into a he said she said on this. I have also done sorne digging into how it appeared on the agenda, 

which is different than your statement below. Also, I've asked how long it was available and who had the agenda in 

advance of the meeting, Suffice to say, I've talked to Torn and ]Vlatt about sensitivities here and they are aware of my 

overall concern that we not discuss ·what may be in deliberation in the Chainnan 's office. 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, March 7, 2019 9:08 AM 

To: Gill, Michael 

Cc: Alex Albert; Thornton, Charlie 

Subject: Inter market surveillance meeting 

Mike: 
I got the agenda for the meeting where our info was disclosed and it looks like Tom put it there himself. I 

think this raises a bigger question of intent. Obviously ifwe had known we would have sent someone who knew 

about what we were thinking. 

i.d ~;,>~~-::-=- ::::.<~:h"\;/: (A-;;:d ofr~t::r\\·'~:~~-t::. j-~ yo~: j-~tf,/~~ t~~a~~'.)P tc: bt::Ue,.,~~ you t:r-;;: 

~-.::~;:,>~~-::::~ < -~; ~:::: --.:f-;•;~ :;--.:~: d-; >=~~:~:~.---.:~ :;·~~:-.:::·~\,::: ~- .,.·v: tff~~y\. ~nc: 

~ r:·). h:; ::~-~;b~~jdj:~lde~:; ~ ~~>~ s.., .. ;•: ~-.-=-·~;~-~-:-~~:~ ,:-. ~.-, .. ;-~ :;·;·::~~>~ d:· ~1~b;d: ~:·c ;_ Ur:f;:nc ypt~::d e~ec-t:\-::r+: ff:i:dj l~:; not r;:.=;; _;Ut(~ ,::t:d ;;~c tc, .. ;;: .. ) ·::-nt of "tj : ~:d:::::;~.d~Jc ;-.-:. 

e:<p~:::~~t~:::d tc p:\>vkk st:J::.:qut:t\k~ fr~;n·~ ..,_,. =-tJ~:;e'.::: Hnd pui ~.~_ie t:lternt:h.: n-~~~:~~n~~ or convn~.mkatk>n v~here pn\/t:~~v a bindinn :·~:::.~'.-:>'.::;:~u~~ :,-. +·:.- 0 ::; 

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C't. ).":> :~· /~h:._;:";• :•:h 

<:~,.;);~::::~\ .... :.; :.h;-> ''""""""""'' pl~:::~~~~e dehA~::: :t Hnd n::.tJy the ~~.enzk:t. Thi~~. rn::.::~:~~are n·k(/ not repn~:~~ent the op!~ k;n of intet.:. .. :.~···~:n::.:t/\/ i~~xch~~n9e, i ~::. .. 

(lCE). h~ ~~utr~.ldl~~rie~~ net tr::n~tH'ute t: ::.::r.::n~t'~~ct ot qut:Vi~nk~:::. Un::.:nctypL:d decttGn:::.: rn~~il i~~ net s~:::~~u {: an::.~ ~rv: r,~:~~ipbnt ei thi~~ n·K:~~.~~w;n 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 3/7/2019 12:25:49 PM 

To: Gil l, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ient s/ en =3a b6b606c58b45fe8b917 4d248b3fa65-G ii I, Mi cha el] 

CC: Alex Albert [Alex.Albert@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipient s/cn=2f7cd l b27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: Inter market surveillance meeting 

No that would allow Tom to mumble. LL Cool J unplugged. I think Tom could do Going Back to Cali 

acapella. 

From: Gill, Michael <MGill(a),CFTC.g9.~1> 

Date: Thursday, Mar 07, 2019, 12:23 PM 

To: Trabue Bland <Trabue.Bland(a.)theice.com> 

Cc: Alex Albert <Alex.Albertra)theice.com>, Thornton, Charlie <cthornton(lV.CFTC.gov> 

Subject: RE: Inter market surveillance meeting 

\V ARNING - External email from cftc.gov 

I would object to that agenda item but would allow anything by REM pre the Green album. 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, March 7, 2019 11:55 AM 

To: Gill, Michael 

Cc: Alex Albert; Thornton, Charlie 

Subject: RE: Inter market surveillance meeting 

Sorry I didn't mean that! It was a pretty reasonable assumption that the CFTC set their agenda though. Now 

knowing this I think I will add under the CFTC agenda: Acapella rendtion of Queensryche 's seminal 1988 

album Operation Mindcrime. I look forward to Tom's version of Revolution Calling. I think it will spice up 

the meetings. 

Just joking-thanks again for following up. 

From: Gill, Michael <MGilValCFTC.goy> 

Date: Thursday, Mar 07, 2019, 11:41 AM 

To: Trabue Bland <Trabue.Bland@theice.com> 

Cc: Alex Albert <Alex.Albert@theice.com>, Thornton, Charlie <cthorntonra)CFTC.gov> 

Subject: RE: Inter market surveillance meeting 

\VARNING - External email from cftc.gov 

I'd prefer to not get into a he said she said on this. l have also done some digging into hcrw it appeared on the agenda, 

which is different than your statement below. Also, I've asked how long it was available and who had the agenda in 

advance of the nieeting. Suffice to say, I've talked to Tom and JV[att about sensitivities here and they are aware of my 

overall concern that we not discuss what may be in deliberation in the Chairman's office. 
I 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, March 7, 2019 9:08 AM 

To: Gill, Michael 

Cc: Alex Albert; Thornton, Charlie 

Subject: Inter market surveillance meeting 

Mike: 

I got the agenda for the meeting where our info was disclosed and it looks like Tom put it there himself. 

think this raises a bigger question of intent. Obviously ifwe had known we would have sent someone who knew 

about what we were thinking. 

urJe~~.~~ exph::.::~tj~/ nokd othef\:\:·j~~e y::.::.1 h:r:.::-; ~ .. -: .. -;._..,'-~~. ~o b::.:Hev~~: you H:·~::: 

2-:·J n(::~ :\:p:·~:::H.:nt th.: ~;pink::n of jnk::::·::. •.-,•-;:._ ,::.~··, ❖·:) :·:·<t~:,:..: ... (;::.~, :r,::_::_ 

<:~,.;);~::::~\ .... :.; :.h;-> ''""''""''"'' pj~:::~~~~e dehA~::: :t Hnd n::AW/ the ~~.enz:je:·. Thi~~- rn::.::~:~~aqe n·k(/ not repn~:~~ent the opj~ ;u~·-: u; ;)=·~~:::=, •.-,•-;:---,::.~--, ❖-,) =·:·<t~>:..: ... (;::.~. = ~::.-. 

(lCE). h~ ~~utr~.ldl~~rie~~ net tr::n~tH'ute 2.: ::.::r.::n~t'~~ct ot qut.:Vi~nk~:::. Un::.:nctyph.:d dect:\)n:::.:: rn~~il i~~ net s~:::~~u e an::J ~rv: r,~:~~ipl~:::nt ci thi~~ n·K:~~-~~w;n 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 3/6/2019 2:15:54 PM 

To: Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gill, Michael]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

CC: Alex Albert [Alex.Albert@theice.com] 

Subject: RE: Confidential information disclosure 

BTW, just seems something Tom would not have done. Who knows I guess. I will find out who put Bakkt on the 

agenda. Thanks. 

From: Gill, Michael <MGill@CFTCgo11> 

Date: Wednesday, Mar 06, 2019, 2:11 PM 

To: Trabue Bland <Trabue.Bland(a)theice.com>, Thornton, Charlie <cthornton(ii1CFTC.gov> 

Cc: Alex Albert <AleicAlbert@lt.heice.com> 

Subject: Re: Confidential information disclosure 

WARNING - External email from cftc.gov 

I spoke to Tom this morning, but I've gone from mtg to mtg and have not had a chance to call you. Tom reported 

Bakkt was on the agenda that is why he addressed it, not sure who put it there. Tom had a pretty prepared response 

even though we spoke at a quarter to eight this morning so I think he \Vas aware of the concern. But, I made it known the 

Chairman does not want discussions on our internal deliberations or the matter generally to be discussed outside the 

bldg. 

On: 06 March 2019 14:07, 

"Trabue Bland" <Trabue.Bland(wtheice.com> wrote: 

Mike-just checking to make sure that staff (or a staffer) knows not to discuss our internal business strategy. Thank you 

in advance. 

Trabue. 

From: Gill, Michael <MCill@lCFTC.gov> 

Date: Tuesday, Mar 05, 2019, 5:52 PM 

To: Trabue Bland <Trabue.Bland(Z:Dtheice,eom>, Thornton, Charlie <cthornton@CFTC.gov> 

Cc: Alex Albert <Alex.Albert@ltheice.com> 

Subject: Re: Confidential information disclosure 

WARNING - External email from cftc.gov 

What call? What industry? 
On: 05 March 2019 16:26, "Trabue Bland" <Trabue.8tand@th€lce.com> wrote: 

I have an understanding that a CFTC staffer disclosed sensitive, confidential ICE information including our 

BAKKT strategy on an industry call this morning. Can we discuss ASAP? 

Trabue 

Trabue Bland 

President, !CE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street, 40th Floor 

Telephone; +1 770.916.7832 (Atlanta) +1 212.748.4005 (New York) 

Mobile: L ............. (b)(6) ···--·--·--·' 

trabue.bland@theice.com 

intercontinentalexchange.com 

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Message 

From: AAC [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AAC4E6] 

Sent: 3/4/2019 3:50:33 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; AAC 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=AAC4e6] 

Subject: RE: Nomination for Agriculture Advisory Committee 

,-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· 

Non-Responsive 

From: Thornton, Charlie 

Sent: Monday, March 4, 2019 3:38 PM 

To:AAC 

Subject: RE: Nomination for Agriculture Advisory Committee 

.·-·-·-·-·-·-·-·-·-·-·-·-·-·-

i 

·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-. 

Non-Responsive 1 

....................................................................................................................................................................................................................................................................................................................................................................................... ·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·· 

From: AAC 

Sent: Monday, March 4, 2019 3:37 PM 

To: Thornton, Charlie 

Subject: FW: Nomination for Agriculture Advisory Committee 

.·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·~ 

' ' 

I Non-Responsive I i·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-i 

From: Alex Albert [mailto:Alex.Albert@theice.com] 

Sent: Monday, March 4, 2019 9:22 AM 

To: Trabue Bland; AAC 

Cc: Tim Barry; Thornton, Charlie 

Subject: RE: Nomination for Agriculture Advisory Committee 

Thanks gain, Christa. Can talk more about Mike if needed, but Technically I should have pegged him to 

Imperial Sugar Company (not Louis Dreyfus even though they are the holding company). 

Good luck! Alex 

From: Trabue Bland <Trabue.Bland(a)theice.com> 

Date: Monday, Mar 04, 2019, 9:13 AM 

To: AAC <AAC(w.CFTC.gq_y>, Alex Albert <Alex.Albert(a).theice.com> 

Cc: Tim Barry <Tim.Barry(iz),Theice.com>, Thornton, Charlie <cthornton(al.CFTC.gq_y> 

Subject: RE: Nomination for Agriculture Advisory Committee 

Thanks Chdst:a. I think you will have a good committee! 

From: AAC [mailto:AAC@CFTC.gov] 

Sent: Friday, March 01, 2019 9:12 AM 

To: Alex Albert <Alex.Albert@theice.com>; AAC <AAC@CFTC.gov> 

Cc: Tim Barry <Tim.Barry@Thelce.com>; Trabue Bland <Trabue.Bland@theice.com>; Thornton, Charlie 
<cthornton@CFTC.gov> 

Subject: RE: Nomination for Agricult ure Advisory Committee 

WARNING - External email from cftc.gov 

Received - thanks very much, Alex! 

Regards, 

Christa Lachenn1ayr 

Division ofl\farket Oversight, 1J.S. Commodity Fu:tures Trading Commission 

u5:::; '.?1" NvV I DC I T'ci; ?G'.?Jl I https://secure.ice/?vvww.cftc.gov 

If vou are not .. .•· ' 

COlllIIlUIUCat:~()11 lll error} 

From: Alex Albert [mai lto:Alex.Albert@theice.com] 

Sent: Thursday, February 28, 2019 6:52 PM 

To:AAC 

Cc: Tim Barry; Trabue Bland; Thornton, Charlie 

Subject: RE: Nomination for Agriculture Advisory Committee 

Sorry. This is Charlie's correct email address. Please use this one and thanks. Alex 

From: Alex Albert <Alex.Albertra)theice.com> 

Date: Thursday, Feb 28, 2019, 6:28 PM 

To: aac(a).cftc.goy <aac(al.cftc.gQ_y> 

Cc: Charlie Thornton (cliarliethorntonl(a>gmail.com) <charliethorntonl(iz),gmail.com>, Tim Barry <Tim.Barrvra).Thelce.com>, 

Trabue Bland <Trabue.Blandra),theice.com> 

Subject: Nomination for Agriculture Advisory Committee 

To Whom It May Concern: 

Please find enclosed a nomination for Mike Gorrell of the Louis Dreyfus Company to serve as a member of the CFTC 

Agriculture Advisory Committee. I have attached a link to Mike's short bio and a written copy. We are happy to provide 

a more extensive biography or further information upon request. 

In summary, Mike is a trusted partner of ICE Futures US and has played a constructive role with the exchange and the 

CFTC in helping develop position limit proposals. These efforts with the Commission have focused on the global nature 

of the sugar market and the unique hedging needs of participants this brings. Mike has first -hand knowledge of the 

"soft'' agricultural product markets and tailored hedge exemption provisions necessary for their proper functioning. 

Undoubtedly Mike would be an asset to this group of advisors, particularly on hedging and position limit discussions, 

and we give him our strong recommendation. In addition, please consider the unique needs of soft agricultural markets 

and, given his extensive experience, the constructive role Mike could play with such a focus. Thank you for your 

consideration. 
Sincerely,, 

Alex Albert 

Intercontinental Exchange 

Washington, DC 

https://secure.ice/?https://sugaralliance.org/asa-symposium-2018/gorrell 

Mike Gorrell 

President and CEO 

Imperial Sugar Company 

Alex Albert 

Intercontinental Exchange 

(202) 661-8942 (w) 

i (b)(G) !(c) l---·-·-·-·-·-·-·-·-·-·-·-·-·-·-· 
Message 

From: Alex Albert [Alex.Albert@theice.com] 

Sent: 2/28/2019 5:49:43 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOH F23SPDL T)/cn=Hedpients/cn=2f7cdlb2 7f3e4 fde80a5088eadd3b931-Thornton 111 , Norwo) 

CC: Trabue Bland [Trabue.Bland@theice.com] 

Subject: As discussed 

---·-·-----·--·--·-·-·-·-·-·-·-·-----·-·-·-·-·-·-·--·--·-------·--·--·--·------ -----·-·-·-·-·-·-·-·--·--·--·-·-·-·-·----- ·--·- ·- ·-·-·- ·- ·-·-·-· j ! 

i ! i 

i 

; 

i 

l --------·········-···-· --···-· ··-·•-·-·-·-·-· --· -·-· ··-· ··-·--···-· · •-· ··-· ··-·--·--· ··-· ··-· ··-· -···-· ··-··-· ··-· --·--· -·-· · •-· ··-·--···---··-· ··-· --·--· -·- ··-· ··-·--···-· ··-· ··-·-·-·-·-·--· -·-· ··-· -·-· --···-· -----------·. 

Alex Albert 

Intercontinental Exchange 

(202} 661-8942 (w) 

i 

1. ........ ....

(b)(6) j(c) ........... ........ . ................... + 

·nm~ rn~s~.age nv.1y *:,o:1b::in {.~IJ;di:..;JltmJ mk>rrna°'-:,n .and is li\~~rv.i~ 10-r sox:~.Hk: r.-idp1ei:ch. tJfll€S-S e•xpfrdtf:,- t,otx:.:f ytt)er\'•lse ~ J ~fli \)ave n.:'i~":wn io )t..xiie~e-yo1.1 ~:.: 

r:~~t ar~ k1tnt~,k:;.:i 1'ti~tp~s :1t t)f this ~Ylu,.sa§~ ~ p!;;~se lleiet~i ;t a~ r·,ct fv li~ J~JH\®r ~ Tli,:t r:l)tJS'::i3Ue- ~~ay n<il rep~~en~ the or.{:i:.i,:W'; ot 1!'1te~:otff:~r:t..3⁄4'.)tai Eff.,htH)gt;, ~nc 
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: · >>,s:-c ..... ;--=-- j::::; :_:k:;::;lred 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/27/2019 9: 14:37 PM 

To: Kelly Loeffler [Kel ly.Loeffler@bakkt.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Alex Albert 

[Alex.Albert@theice.com]; Trabue Bland [Trabue.Bland@theice.com] 

Subject: Re: Agenda for tomorrow 

No we can wait until after. I put it in there just for you to say you are working and will share in the coming 

days. 

On: 27 February 2019 20:58, "Kelly Loeffler" <Kdiv.Loeffier@bakkt.com> wrote: 

Thank you Charlie. Do you want to see the draft of the post for the meeting or is after OK? 

Best, 

Kelly 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Wednesday, February 27, 2019 5:07 PM 

To: Alex Albert <Alex.Albert@theice.com>; Trabue Bland <Trabue.Bland@theice.com>; Kelly Loeffler 

<Kelly.Loeffler@bakkt.com> 

Subject: Agenda for tomorrow 

\VARNING- ExternaJ email from cftc.gov 

Excuse the weird font /format. I am sending this from my phone. Please let me know if you have any 

questions. 

Agenda: 

IFUS Draft Submission 

ICUS Draft Submission 

FCM Issues: 4d Customer Property, Segregation, Bankruptcy Treatment 

Warehouse Regulatory Status/Disclosure 

ICE Press Release 

Wrap Up/ Discuss Next Steps 

~-inie~~~~- exp{dUy noted oJi(~:r\.-•/:S(~: y~;~.l ht:\/e reason to b:::lk:'.-'e ":/Z>L: ~~:\: 

n::A =·~:::p:\::~:~:::n~ th~::: G~Hn:Gn o! >:>~::\,,.._\ =·-;~·:~~=:L ) Exz)~anrr:::, 

Message 

From: Thornton, Charlie l/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/27/2019 5:04:33 PM 

To: Trabue Bland [Trabue.Bland@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo}; Alex Albert 

[Alex.Albert@theice.com]; Kurt Windeler {Kurt.Windeler@theice.com) 

CC: Marvine, Charles D. [/o=CFTC/ou=Chicago/cn=Recipients/cn=cmarvine] 

Subject: Re: KC Ag Conference 

Great! Copying C huck Marvine, he runs our KC office and is handling this conference. 

On: 27 February 2019 16:47, ttTrabue Bland" <Irn.9.V.£,m.~n.4.@JJ1_t;f<;;_9._. __ <;.Qm.> wrote: 

Charlie--

Following up on your earlier email, Kurt Windeler will participate on the panel next week. Kurt rocks these 

things, so I know he will be good. Thanks! 

Trabue Bland 

President, fCE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street, 40th Floor 

Telephone: +i 770.916.7832 (Atlanta) i +1 212.748.4005 (New York) Mobile: (' ......... _. (b)(6}• .· . . .. i 

trabue. b1ana@tnerce:com··' 

intercontinentalexchange.com 

11,t~} :'4!~;;-;,HJ.i.9!'\:: n·:a~y tX>~lt<~it~ ~-crii-".h::rt!:,i;~ !r1f·rn·n-:;,itie>t, f:l:'td r;.. =t~t!?-t)C:Ud f{tf 'sf'.l-i~~:i h~ if'!~}:l):Cf':t!} :.mil~1⁄4 -oxp,fk!t::i ~·':~tt><i :>tr1,:H'W:~1;: (f Y(:U h~:Vi~ re~Sf,;V.: {<) tH::ii-::Vl?' v~>ti ,hrt~ 

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ttCE)1 ft,;. ~:J!:~i=~1~.a:1,B~ ()( .i.tf~:i.;~l-::m, dt~d ~1<s1:~;. ~1,rt c:~!l>-i.l=tr.:i<; ,3. f'.,-:''.:f~~ra<.i' ~,r g:..!<~r~::~itee t k~r::rtt;~y1,h:~d eiG(.irf1rfrt ~~;~~ I& ~1,rt ~}e ~Ufl:- ~:rici ;ht?- r~~~lp=e~,t nf ~?1::~ ='rt::~;..~~gt~ i:s. 

~?' .<pi:H:~.t!::'-'S tc .pro••/1()1;.: s~:to-;t.:.=:rd~;. n°3⁄4>rn •l :t ~Ji;.e~ ~H':d J,tH~W~ :::tb: f~),.;tte r(''t:..i}rJt;: nt t>ormT:urtiwi;;{~>n vhere ~'lV1!~:;.y ,>f ~ t1h··~iri'!J :"rtE~~t,;~g~ h, ~]~!:!HH~d 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/27/2019 8:51:33 AM 

To: Thornton, Charlie [/o=CFTC/ ou=Exchange Adm inistrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com] 

CC: Gil l, Michael [/o=CFTC/ou=Exchange Admin istrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gil I, Michael]; Gorfine, Daniel 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =fec0394154854e leac5fb409856e5 le8-Gorfi ne, Daniel] 

Subject: RE: Diagrams 

Sure----g1ve me a few minutes to find out what Erik sent over---thanks! 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Wednesday, February 27, 2019 8:49 AM 

To: Alex Albert <Alex.Albert@theice.com>; Trabue Bland <Trabue.Bland@theice.com> 

Cc: Gill, Michael <MGill@CFTC.gov>; Gorfine, Daniel <DGorfine@CFTC.gov> 

Subject: Diagrams 

\VARNING- ExternaJ email from cftc.gov 

Can you send us the diagrams you have put together? They were just referenced in a meeting we are having. 

<:~,.;);~::::~\ .... :.; :.h;-> ''""''""''"'' pl~:::~~~~e dehA~::: :t Hnd n::.tJy the ~~.enz:i::.:r. ·r}is tnes~~-~~re n·k(/ not repn~:~~ent the c:plnk::n of lnter::.::r::n~:nentaf i~~:<chanqe, i ~::.-. 

net tr::n~tH'ute t: ::.::r.::n~t'~~ct ot qut:Vi~nk~:::, Un::.:nctyph.:d dect:\)n:::.:: rn~~il i~~ net s~:::~~ure and Jv: r,~:~~ipl~:::nt ci thi~~ n·K:~~-~~w;n 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/26/2019 12:41:16 PM 

To: Alex Albert [Alex.Albert@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: ICE Rep at AgCon 

I will confirm with Kurt but we should be good--

From: Alex Albert 

Sent: Tuesday, February 26, 2019 10:32 AM 

To: Thornton, Charlie <cthornton@CFTC.gov> 

Cc: Trabue Bland <Trabue.Bland@theice.com> 

Subject: RE: ICE Rep at AgCon 

Good idea 

From: Thornton, Charlie <cthorntonraiCFTC.gqy> 

Date: Tuesday, Feb 26, 2019, 10:30 AM 

To: Alex Albert <Alex.Albert(a)theice.com> 

Cc: Trabue Bland <Trabue.Bland0)theice.com> 

Subject: RE: ICE Rep at AgCon 

WARNING - External email from cftc.gov 

Copying Trabue. 

From: Alex Albert [mailto:Alex.Albert@theice.com] 

Sent: Tuesday, February 26, 2019 10:27 AM 

To: Thornton, Charlie 

Subject: RE: ICE Rep at AgCon 

Trabue, are we set on Kurt Windeler for this? 

From: Thornton, Charlie <cthornton(lV.CFTC.gov> 

Date: Tuesday, Feb 26, 2019, 9:24 AM 

To: Alex Albert <Alex.Albert(iz),theice.com> 

Cc: Marvine, Charles D. <cmarvineiiz).CFTC.GOV> 

Subject: ICE Rep at AgCon 

WARNING - External email from cftcogov 

Alex, 

Can you connect us with the person you wish to serve on our matching alga panel at the Ag Conference? 

Thanks! 

Charlie 
.1·\·'i ~>J:1lz?:," 

~.._:'.._.-u,s:_~,11. ,,/~;I~,'"""''"''"""" 
Appointment 

From: Gill, Michael 1/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=3AB6B606C58B45FE8B9174D248B3FA65-GILL, M ICHAEL) 

Se nt: 2/26/2019 8:29:45 AM 

To: Giancarlo, Chris [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Giancarlo1 

Chds2a4); Kelly Loeffler [Kelly.Loeffler@theice.com]; Bussey, Brian [/o=CFTC/ou=E.xchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Zaidi, Amir 

1/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi); Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kulkin, Matthew]; Sklar, Magg1e 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipient s/cn=Sklar, Maggieca3]; Thornton, 

Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; AlexAlbert 

[Alex.Albert@theice.com]; Trabue Bland [Trabue.Bland@theice.com]; Kelly Loeffler [Kelly.Loeffler@bakkt.com); 

Goodman, Chris [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Goodman, 

Chris269]; Hester Serafini [Hester.Serafini@theice.com); Kuserk, Gregory 1/o=CFTC/ou=Washington, 

DC/cn=Recipients/cn=gkuserk); Karen Wu.ertz [KWuertz@NFA.Futures.Orgl 

Subject: CHC warehouse review call 

Attachments: invite.ics 

Location: Dial-in: 866-564-2207 Participant Codet._, ___ J_b)(4) ···-·_J 

Start : 2/28/2019 9:00:00 AM 

End: 2/28/2019 10:00:00 AM 

Show Time As: Tentative 

Recurrence: (non~) 

When: Thursday, February 28, 2019, 3:00 PM to 4 :00 PM. Eastern Time 

Where: Dial-in: 866-564-2207 Participant Code:l (b)(4) l '-·- •- ·-····-- <- · ·-- ·- -- ·- ·- •- .- •- --

*-*-*~*~*- *~*~*~*~* 

If it is not too much trouble, the Chairman would like to move this call to 9:00 a.m 
Message 

From: Kelly Loeffler [Kelly.Loeffler@bakkt.com] 

Sent: 2/22/2019 5:45:37 PM 

To: Gil l, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipient s/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gill, Michael]; Giancarlo, Chris 

[/o=CFTC/ou=Exchange Admin istrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Giancarlo, Chris2a4]; Bu ssey, 

Brian [/o=CFTC/ou=Exchange Ad ministrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Za idi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi]; Kulkin, Matt hew 

[/o=CFTC/ou=Exchange Admin istrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Sklar, Maggie 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Sklar, Maggieca3]; Thornton, 

Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com]; Trabue Bland [Trabue.Bland@theice.com]; Fred Hatfield (External) 

[fwhatfield@comcast.net]; Adam White [adam.white@bakkt .com]; Erik Haas [Erik.Haas@bakkt.com] 

Subject: RE: Fol low Up From Warehouse Mtg 

Mike, thank you for the summary. We're in agreement and I know everyone is working hard to resolve the open items. 

Regards, 

Kelly 

From: Gill, Michael [mailto:MGill@CFTC.gov] 

Sent: Thursday, February 21, 2019 6:58 PM 

To: Giancarlo, Chris <JCGiancarlo@CFTC.gov>; Kelly Loeffler <Kelly.Loeffler@bakkt.com>; Bussey, Brian 

<BBussey@CFTC.gov>; Zaidi, Amir <AZaidi@CFTC.gov>; Kulkin, Matthew <MKulkin@CFTC.gov>; Sklar, Maggie 

<MSklar@CFTC.gov>; Thornton, Charlie <cthornton@CFTC.gov>; Alex Albert <Alex.Albert@theice.com>; Trabue Bland 

<Trabue.Bland@theice.com>; Fred Hatfield (External) <fwhatfield@comcast.net> 

Subject: Follow Up From Warehouse Mtg 

WARNING - External email from cftc.gov 

Thanks again for this morning's productive meeting. To recap, I believe the following tasks were agreed to today: 

(b)(4) 

Please forward this as appropriate and let me know if I have not captured our tasks correctly. l will send around a call 

invite shortly. 

Mike 

C'tdef o:f Staff 

f)(: 20581 
.1·\·'i ~>J:1lz?:," = __ "):"{·~\..: ~',y· ;-:c=:>~~,•-.y:r: 

~.._:'.._.-u,s:_~,11. ,_/~;I~,'"""''"''"""" !ete ~:ind 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/20/2019 11:26:00 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDL T)/cn=Recipients/cn=2f7cdl b27f3e4fde80a5088eadd3b931-Thornton 111 , Norwo J; Mika Kawana 

[Mika.K,;1wana@theice.com] 

CC: Alex Albert [Alex.Albert@theice.com l 

Subject: RE: Meeting: CFTC I Bakkt 

Cool- let me know! 

From: 1110mton., Charlie <cthorntonrii1.CFfC,gov> 

Date: Wednesday. Feb 20, 2019. 11 : 12 AM 

To: Mika Kawana <Mika.Kawana@theice.com>, Thornton, Charlie <cthooiton(@CFTC.go,-> 

Cc: Alex Albert <Alcx.Albcrl1@t11eice.co111>, Trabue Bland <Trabue.Bland(@theicc.com> 

Subject: Re: Meeting: CFTC I Bakkt 

WARNING - Ex.termtl email from cftc.gov 

Hey, I was on the phone with Alex, when you called. He has a new plan. 

On: 20 February 2019 09:34, "Mika Kawana" <Mika Kawana(@theice.com> wrote: 

Hi Charlie. 

1 Ji ope ail ls well! Would ~UOa ET to111orrow, Fobmary 2 J work for a call v..0ith Kelly and a few other people? 

111a11ksl 

Mika 

Mika Kawana • Manager, Corporate Affairs 

Intercontinental Exchange ,I ICE 

5660 New Nonhslde Or. I 3rd Floor I Atlanta, GA 30328 

Tel: 4-'1 770.857.7087 I Mob: {~-----(b)(Gf ___ __ _ i 

mika. kawana@theice.com •·-··-·-·-·-·-·-·-·-- -·-·--·-·-·-­

intercont.inentalexchange, com 

r-, } * 

t, ice NYSE 

············-··················-············· ····-··-··-··-··- -··-··-···········-··-········-··-··-···········-··········---·-··············-··········-----·····-·············-·············· ·-··-·---··-··-··-·---··-··--

From: Mika Kawana 

Sent: Tuesday, February 19, 2.019 5:47 PM 

To: 'Thornton, Charlie' 

Cc: Alex Albert; Trabue Bland 

Subject: RE: Meeting: CFTC I Bakkt 

l hear you! Do we want to spend the time we have blocked tomorrow on thv phone? And I thrnk you are here - do ~ou 

w..u:tt to s,"ing by and meet in pcrso11 with a few people'! 

1l1an.ks! 

Mika Kawana - Manager., Corporate Affairs 

Jntercontinental Exchange l ICE 
5660 New Northside: o r, I 3rd Floor .l._At!.anta, GA 30328 

Tel: +1 770.857 .7087 Mob: i (b)(6) l 

mik a, kawana@theice.c1 om '·· ·· ····~···-·-·--'············--·--? 

intercontinentalexchange.com 

·~.-· I * " . 

i tee NYSE 

from: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Tuesday, February 19, 2019 5:46 PM 

To: Mika Kawana 

Ct: Alex Albert; Trabue Bland 

Subject: RE: Meeting: CFTC I Bakkt 

WARNING - Externaf email from cftc.gov 

We should cancel tomorr:ow. I think t hat even if t hey can get out of DC, I think the worry is that they wiH not be able. ta 

get back to DC. However. we want to block out some time to harnmer out some issues via the phone m the next few 

days. 

From: Mika Kawana [mailto:Mika.Kawana@theice.com] 

Sent: Tuesday, February 19, 2019 3:35 PM 

To: Christina Canfield; Kelly Loeffler; Rich Mackey (External); Richard Mackey; Erik Haas; Chris Michels; Adam White; 

David Clifton; Alex Albert; Trabue Bland; Matthew Mehalso; Jefftey Sprecher; Mark Wassersug 

Cc: Thornton, Charlie 

Subject: RE: Meeting: CFTC I Bakkt 

Hi -all . 

Tl1l' weather is not looking great in DC t<m101Tow Char:!ie will keep us posted, but we arc currentl1 putung ton11'.>rrow 's 

meeting in the TBD categoty given possible flight cancdlations. 

Charlie or I will cfrcle back 

Thanks! 

Mika 

Mika Kawana - Manager, Corporate Affairs 

Intercontinental Exchange f ICE 

5660 New Northside Dr. I 3rd Floor l Atlanta, GA 30328 

Tel: +1 770.857.7087 I Mob: r ·· ···-··· ···tb)(6)·····-···-··•-7 

mika.kawana@theice.com •-•--- -- ··-···-·--·-•- --~-.-·-·' 

intercont inentalexcha nge. com 

-----Original Appointment--­

From: Christina Canfield 

Sent: Thursday, February 14, 2019 11:26AM 

To: Christina Canfield; Kelly Loeffler; Rich Mackey (External); Richard Mackey; Erik Haas; Chris Michels; Adam White; 

David Clifton; Alex Albert; Trabue Bland; Matthew Mehalso; cthornton@CFTC.gov; Jeffrey Sprecher; Mark Wassersug 

Subject: Meeting: CFTC I Bakkt 

When: Wednesday, February 20, 2019 10:45 AM-3:15 PM (UTC-05:00) Eastern Time (US & -Canada). 

Where: ICE Atlanta I The High Conference Room I Oral in below 
2/18- attendees update, agenda and dial in added 

Agenda added below. 

Dial in information 

Internal extension: 8888 

Meeting ID: 708?# 

Password: l.__(b)(4)_J 

External numbers: 

us 

Atlanta 1-770-618-8888 

Chicago 1-312-596-4412 

Houston 1-713-815-7276 

New York 1-212-896-2810 

CFTC Attendees 

Charlie Thornton, Director of Legislative Affairs 

Mike Gill, Chief of Staff - Chairman Giancarlo 

Daniel Gorfine, LabCFTC Director 

Brian Bussey, Director of OCR 

Bakkt Attendees 

Kelly Loeffler, CEO 

Rich Mackey, President18 

Adam White, COO 

Erik Haas, Director, Compliance 

Chris Michels, Director, Custody Operations 

Intercontinental Exchange Attendees 

Jeff Sprecher, Chairman & CEO - TBD 

Mark Wassersug, COO 

Trabue Bland, President, ICE Futures U.S. 

Alex Albert, Co-Head Government Affairs 

Matt Mehalso, Manager, ICE Clear Dev, Technology 

Jerry Perullo, Chief Information Security Officer 

Sachi Pati, Senior Director - Clearing Technology 

RJ Cummings, VP - Product Development 

Centennial Conference Room also booked for a breakout room as needed. 

Lab CFTC Agenda 

February 20 

10:45 a.m.-11:00a.m. 

Intro - Bland/Albert/Loeffler [note: KUAW(?) leaving at 11am for Bakkt board meeting until -Noon) 

• People in the room 

• Lab CFTC 

; ' '---·---- - ------------•-· -- -----·---.----·-------------·-----•-·--· -·-· --- . --·----------·- -·-· ------------. - ---·--· -·------·- ---·------·----- ~--------·- -·- -•-·i 
I -•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-

! 
.... ~ _ , ... , ....... ,❖, ❖ ... :-. t: ::.::(::n~r~~ct o:· qut:t\~:~t ~:~:; , ~- ) :,: = L= d-:~·,: .... t ~:.;~::: ..... -=-= -...n ::-...: 

~:rnat~:; = L-:..~d) :S u; ,·:.c,~-,--,,-> ·+:?; :: _., ;_\':·' ~:t\::: ~H'i'.-'a::.::·:/ 

nc,L::d uti ici ~):i;: ~f \ -...,:.: ;?-:.·e th:~~sc,;) t,,) bc;k~,:e '/'.)U ;:~rt:: 

~ ~~;~ : c;v-: t::~~c) :; ;;1c ~;~s;~:;~;:1 ~;;· ;) :;(;;.i · .. ~;~:-~;) =~:~: ~;-,:~; ;":~::<~ .. ;1,:~;>p:~ 

{:(...['1. \::::: ~~·/H:+:-.:'/i>­

t::\~:,.:;- .;~,-:'.-~.; \,) f' :'()\. kk: ~-=-d-~:!~F 
Appointment 

From: Christina Canfield [Christina.Canfield@bakkt.com] 

Sent: 2{19/2019 6:12:58 PM 

To: Kelly Loeffler [Kelly.Loeffler@bakkt.com]; Rich Mackey (External) (rmackey@rcgdirect.com]; Richard Mackey 

[Richard.Mackey@bakkt.com]; Erik Haas [Erik.Haas@bakkt.com]; Chris Michels [Chris.Michels@bakkt.com]; Adam 

White [adam.white@bakkt.com]; David Clifton [David.Clifton@theice.com); Alex Albert [Alex.Albert@theice.com]; 

Trabue Bland [Trabue.Bland@theice.com); Matthew Mehalso [Matthew.M ehalso@theice.com); Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDL T)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton 111 , Norwo]; Jeffrey Sprecher 

[Jeffrey.Sprecher@theice.com); Mark Wassersug [Mark.Wassersug@Thelce.com]; Jerry Perullo 

ijerry.perullo@theice.com]; Sachi Pati [Sachi.Pati@theice.com); RJ Cummings [rj.cummings@theice.com I 

CC: Kara Dutta [Kara.Dutta@theice.com) 

Subject: Canceled: Meeting: CFTC I Bakkt 

Location; ICE Atlanta I The High Conference Room I Dial in below 

Start: 2/20/2019 10:45:00 AM 

End: 2/20/2019 3:15:00 PM 

Show Time As : Free 

Importance: High 

Recurrence: (none) 

2/18- attendees update, agenda and dial in added 

Agenda added below. 

Dial in information 

Internal extension: 8888 

Meeting ID: 7087# 

····-···-··· -···-···-·······-·1 Password: i (b)(4) l 

External n umoers:·· -···-·····-· 

us 

Atlanta 1-770-618-8888 

Chicago 1-312-596-4412 

Houston 1-713-815-7276 

New York 1-212-896-2810 

CFTC Attendees 

Charlie Thornton, Director of Legislative Affairs 

Mike Gill, Chief of Staff - Chairman Giancarlo 

Daniel Gorfine, LabCFTC Director 

Brian Bussey, Director of OCR 

Bakkt Attendees 

Kelly Loeffler, CEO 

Rich Mackey, President18 

Adam White, COO 

Erik Haas, Director, Compliance 

Chris Michels, Director, Custody Operations 

Intercontinental Exchange Attendees 

Jeff Sprecher, Chairman & CEO - TBD 

Mark Wassersug, COO 

Trabue Bland, President, ICE Futures U.S. 

Alex Albert, Co-Head Government Affairs 

Matt Mehalso, Manager, ICE Clear Dev, Technology 

Jerry Perullo, Chief Information Security Officer 

Sachi Pati, Senior Director - Clearing Technology 

RJ Cummings, VP - Product Development 

Centennial Conference Room also booked for a breakout room as needed. 

Lab CFTC Agenda 
February 20 

10:45 a.m.-11 :00 a.m. 

Intro - Bland/Albert/Loeffler [note: KUAW(?) leaving at 11 am for Bakkt board meeting until ~Noon) 

• People in the room 

• Lab CFTC 

Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/19/2019 5:52:45 PM 

To: Mika Kawana [Mika.Kawana@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

CC: Alex Albert [Alex.Albert@theice.com] 

Subject: RE: Meeting: CFTC I Bakkt 

Can Mike and crew just try to come down? I mean we are all here and no one knows what this storm is doing. 

From: Mika Kawana <Mika.Kawana(il!,theice.com> 

Date: Tuesday, Feb 19, 2019, 5:47 PM 

To: Thornton, Charlie <cthomton(«ilCFTC.gov> 

Cc: Alex Albert <Alex.Alberticz),theice,com>, Trabue Bland <Trabue.Bland(al,theice.com> 

Subject: RE: Meeting: CFTC I Bakkt 

Duplicate 
Duplicate
Duplicate
Duplicate 
Message 

From: Mfka Kawana [Mika.Kawana@theice.com] 

Sent: 2/19/2019 3:32:53 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOH F23SPDL T)/cn=Hecipients/ cn=2f7cd lb27f3e4 fde80a5088eadd3b931-Thornton 111 , Norwo) 

CC: Alex Albert [Alex.Albert@theice.com]; Trabue Bland [Trabue.Bland@theice.com] 

Subject: RE: Meeting: CFTC j Bakkt 

Completely trndersnmd. I'll send a note to the group as a heads up. rm sure we \\ti! talk aga.in soon and :;tay wann l 

Mika Kawana - Manager, Corporate Affairs 

Intercontinental Exohange 'I ICE 

5660 New Northside o r. I 1rd f!oor.J.. Atlanta,. GA 3032.8 

T~l: +1 770.857.70.87 1 Mob: 1 (b)(6) ....... 1 

m1ka, kawana@the1ce.com ................................. , 

intercnntinentalexchange. com 

I 

,ce NYSE 

------------------------------·-------------------------------------------------------------

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Tuesday, February 19, 2019 3:03 PM 

To: Mika Kawana 

Cc: Alex Albert; Trabue Bland 

Subject: RE: Meeting: CFTC I Bakkt 

WARNING - External email from enc.gov 

Just FY!. I am not a weather man, but people are telling me it is supposed to get bad tomorrow in DC. So, meeting l 

think needs to be in the TBD category at the moment, in case flights are canceled. 

From: Mika Kawana [mailto:Mika.Kawana@theice.com] 

Sent: Tuesday, February 19, 2019 2:28 PM 

To: Thornton, Charlie 

Cc: Alex Albert; Trabue Bland 

Subject: RE: Meeting: CFTC I Bakkt 

Hi Charlie. 

Just a heads up that the lunch is $ 16. i 4 per pcrso11. We can take cash or checks made payable to lnccrcontin~ntal 

Exchange. Inc. - whatever is cw;il;'!St. 

Thank you! 

Mika Kawana - Manager, Corporate Affairs 

Intercontinental Exot1ange 1 ICE . 

5660 New Northside or. ! 3rd Fl9.?.!...L~!.~~l)!~\gt.\ 30328 

Tel: 3⁄4-1 770.857.7087 Mob: +11 (b)(6) j 1 

mika .kawana@theice.com ;··············-··············~-• 

interc-ontinenta/exchange.corn ....... r, . i 

Lrce ,, 

From: Thornton, Charlie [mailto:cthornton@CFfC.gov] 

Sent: Monday, February 18, 2019 7:17 PM 

To: Mika Kawana; Thornton, Charlie 
Cc: Alex Albert; Trabue Bland 

Subject: Re: Meeting: CFTC I Bakkt 

WARNING - External email from cftc.gov 

Great. Thank you! 

On: 18 February 2019 17:29, "Mika Kawana" <Mika.Kawana@theice.com> wrote: 

Hi Charlie, 

Great chatting earlier. Please find the dial-in and agenda below. I appreciate you sharing with your team. 

Safe travels and please let me know if you need anything! 

Best, 

Mika 

Duplicate 
Duplicate 
Duplicate 
Duplicate 
Duplicate 
Duplicate 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/19/2019 6:37:12 AM 

To: Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gill, Michael]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kulkin, Matthew]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Gorfine, Daniel 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel] 

Subject: Re:Agenda 

[ Non-Responsive ! 1---·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·· 

On: 18 February 2019 20:14, "Gill, Michael" <MGill@CFTC.gov> wrote: ! ' ! i 

I I ! Non-Responsive i L--·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·· 

On: 18 February 2019 15:57, 

"Thornton, Charlie" <cthornton(a),CFTC.gov> wrote: 

Begin Forwarded Message: 

From: "Alex Albert" <Alex.Albert@theice.com> 

Subject: Agenda 

Date: 18 February 2019 15:53 

To: "Thornton, Charlie" <cthornton(a),CFTC.gov> 

Cc: "Trabue Bland" <Trabue.Bland(a),theice.com> 

Charlie, please find enclosed a final agenda for Wednesday's meeting. Please let us know ifwe are missing 

anything or you have other interests while there. We're open to suggestion. Obviously we have flexibility on 

the front and back ends. We'd like to have at least some discussion at the end for process. Thanks, Alex 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/18/2019 3:36:48 PM 

To: Trabue Bland [Trabue.Bland@theice.com]; Gorfine, Daniel [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel]; Gil I, Michael 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gill, Michael]; Zaidi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo]; Kul kin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =a2d0b8b95a0b46029f13ebead b 73f297-Bussey, Brian] 

CC: Alex Albert [Alex.Albert@theice.com]; Kelly Loeffler [Kelly.Loeffler@bakkt.com] 

Subject: Re: Follow up 

Thank you, Trabue. We will review. 

Talk soon. 

Charlie 

On: 18 February 2019 13:27, "Trabue Bland" <Trabue.Bland@theice.com> wrote: 

Happy Presidents Day. Following up on our calls last week, attached is a memo covering the FCM solution and 

bankruptcy. Also attached is the BTC deposit and trade flows power point I sent last week. 

Thank you again for your time. Please let me know if you have any questions. 

Trabue 
Message 

From: Kulkin, Matthew [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=F973COFE038742B4BB68C3EEAE3F8171-KULKIN, MATTHEW] 

Sent: 2/15/2019 1:07:18 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/en=Recipients/en=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ en=Recip ients/ en =a2d0b8b95a0b46029f13ebead b 73f297-Bussey, Brian] 

CC: Gil l, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/en=Recipients/en=3ab6b606c58b45fe8b9174d248b3fa65-Gil I, Michael]; Gorfine, Daniel 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Reci pients/ en =fec0394154854e leac5fb409856e5 le8-Gorfi ne, Daniel] 

Subject: RE: Trade flows. 

Non-Responsive 

From: Thornton, Charlie 

Sent: Thursday, February 14, 2019 6:46 PM 

To: Kulkin, Matthew; Bussey, Brian 

Cc: Gill, Michael; Gorfine, Daniel 

Subject: Fwd: Trade flows. 

Begin Forwarded Message: 

From: "Trabue Bland" <Trabue.Bland@theice.com> 

Subject: Trade flows. 

Date: 14 February 2019 18:42 

To: "Thornton, Charlie" <cthornton@CFTC.gov> 

Cc: "Alex Albert" <Alex.Albert@theice.com>, "Erik Haas" <Erik.Haas@bakkt.com> 

Charlie: Hope you are doing well. Following up on our call earlier this week attached is a description of the flows into 

the FCM. I hope this makes sense. Let me know if you have any questions. 
Message 

From: Mfka Kawana [Mika.Kawana@theice.com] 

Sent: 2/14/2019 3:21:53 PM 

To: Alex Albert [Alex.Albert@theice.com]; Thornton, Charlie [/o=CFTC/ ou=Exchange Administrative Group 

(FYDI BOH F23SPDL T)/ cn=Recipients/ cn=2f7cdlb2 7f3e4 fde80a5088eadd3b931-Thornton 111 , Norwo] 

CC: Christina Canfield [Christina.Canfield@bakkt.com]; Brianna Holt [Brianna.Holt@theice.com]; Trabue Bland 

[Trabue.Bland@theice.com] 

Subject: RE: February 20- ICE Atlanta 

Perfect. 1l1auks, Chartic1 

Do you want i:1s to add you and your colleagues from the CFTC to the calendar invitc'1 

Also. we will plan on you just reimbursing us for lunch if that works. lf not, we can build in t ime in the agenda for you to 

run down to the cafc. 

Thanks! 

Mika Kawana • Manager, Corporate Affairs 

lntercontrnental Exchange I ICE 

5660 New Northside Or. I 3rd Floor I Atlanta, GA 30328 

Tel: +1 770.857.7087 I Mob: -r···········tb)(6f··········1 

mika. kawana@theice.com '·····-··············•····-···-·-·-•·1 

intercontinentalexchange.com 

~ 

'.{ ~ 

~ # 

1⁄4, ice NYSE 

From: Alex Albert 

Sent: Thursday, February 14, 2019 3:09 PM 

To: Thornton, Charlie; Mika Kawana 

Cc: Christina Canfield; Brianna Holt; Trabue Bland 

Subject: RE: February 20 · ICE Atlanta 

Perfect. Trabue and I jus.t discussed doing from 11-3. Gives you wiggle room. 

Alex Albert 

Intercontinental Exchange 

{202) 661·8942 {w) 

: (b)(6) l(c) "-·-·-·-··-·-,-. -..,-·-·-·-·-·-., ----------------.................................................................................................................................................................... __ From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Thursday, February 14, 2019 3:08 PM 

To: Mika Kawana 

Cc: Chrtstina Canfield; Brianna Holt; Alex Albert 

Subject: RE: February 20 · ICE Atlanta 

WARNING - External email; exercise caution 

Parttelpants: 

Charlie Thornton 

Mike Gill 

Daniel Gorflne 

Brian Bussey 
We will arrive between 10:00arn - 10:30am depending on traffic. Need to leave by 3:15pm. 

let me know if you have any questions. 

Thanks! 

Charlie 

___ , .................................. ------- -----.................................................................................................................................................................... -- From: Mika Kawana [mailto:Mika.Kawana@theice.com] 

Sent: Thursday, February 14, 2019 10:00 AM 

To: Thornton, Charlie 

Cc: Christina Canfield~ Brianna Holt; Alex Albert 

Subject: RE: February 20 - ICE Atlanta 

Tiiat" s perfi:x:t - Kelly wilJ b<.1 a.ble to join from I p-3p so it works out \,\Cll W c have the opt10n of you reimbursing us or 

yoq cau go down to our cafo ,md pay for your owu meal ·- options are always valuable. \Ve can huddlt) on this later! 

Thanks and talk soon! 

Best. 

Mika 

Mika Kawana - Manager, Corporate Affairs 

Intercontinental Exchange I ICE 

5660 New Northside or. I 3rd f_!?,~r __ L.t.\t!~~J:?.~.5?..6, 30328 

T~I: +1 770.857.70_87 1 Mob: [ (b)(6) i 

m1ka.kawana@the1ce.com ·-·-···-·-·-···-·-·-···-·-·-·-·-·-·-·-.J 

intercontinentalexchange.com 

[~~l NYS! 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Thursday, February 14, 2019 9:56 AM 

To: Mika Kawana 

Cc: Christina Canfield; Brianna Holt; Alex Albert 

Subject: RE: February 20 - ICE Atlanta 

WARNING - External email; exercise caution 

Yes! lt has been way too !ong! I wil! be in touch in a few hours with more details. But right now, I would plan lOam .. 

3prn for our window o'f time there. We would nc~ed to pay for our own food. So, .if it is better to go out to eat, when can 

do that. Or we can reimburse you all for the expense. Will be in touch soon. 

Charlie 

From: Mika Kawana [mailto:Mika.Kawana@theice.com] 

Sent: Thursday, February 14, 2019 8:51 AM 

To: Thornton, Charlie 

Cc: Christina Canfield~ Brianna Holt; Alex Albert 

Subject: February 20 - ICE Atlanta 

Hi Cha rlie, 

I hope all is well! rm thrilled I get to see you again -1 feel like it has been ages. 

I think you arc still ·working through your travel plans/ timcline, but please let us know what we can do to help. 

Obviously, we can bring up lunch from our cafe, etc. 
Happy to jump on the phone to chat if easier. Thanks and look forward to seeing you! 

Best, 

Mika 

Mika Kawana - Manager, Corporate Affairs 

Intercontinental Exchan.ge I ICE 

5660 New Northside or. I 3rd Floor_L Atlanta, GA 30328 

T~I: +1 770.857.70.87 1 Mob: l (b)(6) i 

m1ka. kawa na@th e,ce. com ~--·-·-·-·-·-·-·-·-·-·-·-·-···-·-·-·-·; 

intercontin entalexchange. com 

NYSE 

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Message 

From: Mika Kawana [Mika.Kawana@theice.com] 

Sent: 2/14/2019 11:01:48 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Trabue Bland 

[Trabue.Bland@theice.com]; Alex Albert [Alex.Albert@theice.com] 

Subject: RE: CFTC / ICE Visit 

\Ve can easily set-up a dial-in. "I11e video conference room only fits 10, but we will put that room on hold just in case as 

weU. 

'I11anks! 

Mika Kawana - Manager, Corporate Affairs 

Intercontinental Exchange I ICE 

5660 New Northside Dr. I 3rd Floor I Atlanta, GA 30328 

Te I: + 1 77 O, 85 7. 7 0_8 7 I Mob: r·-·-·-·-·-·-·-·-·(bf (Gf -·-·-·-·-·-·-·-·i 

m 1ka, kaw an a@th e ice. com '·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·· 

intercontinentalexchange.com 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Thursday, February 14, 2019 10:59 AM 

To: Trabue Bland; Alex Albert 

Cc: Mika Kawana 

Subject: CFTC / ICE Visit 

WARNING - External email; exercise caution 

We look forward to visiting your headquarters to view your cyber security and other built infrastructure for your Bakkt 

Project. 

We will be available from 10am-3pm on the 20th . Could you please provide an agenda, so that we are prepared for the 

discussion? Also, one of the team members will not be present, so we made need to set up a dial in or video 

conference. We can discuss this later on. 

Thanks! 

Charlie 

<:~,.;);~::::~\ .... :.; :.h;-> ''""''""''"'' pj~:::~~~~e dehA~::: :t Hnd n::AW/ the ~~.enz:je:·, l rm~. rn::.::~:~~aq::.: n 2-:·J n(::~ :\:p:·~:::H.:nt th.: (::pink::n of jnk::::·::. •.-,•-;:---,::.~··, ❖·:) :·:·<t~>~:"'(;::.~.: ~::.-. 

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Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/14/2019 11:00:04 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com] 

CC: Mika Kawana [Mika.Kawana@theice.com] 

Subject: RE: CFTC / ICE Visit 

Great--will do--

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Thursday, February 14, 2019 10:59 AM 

To: Trabue Bland <Trabue.Bland@theice.com>; Alex Albert <Alex.Albert@theice.com> 

Cc: Mika Kawana <Mika.Kawana@theice.com> 

Subject: CFTC / ICE Visit 

Duplicate 

unle::_;s ,~:x-piic:Wv noted oth~:ri.,,.\d::x: _ if vnu ha'-.:'i.:: rix:;Bon h> tK:lk~'-.:'i.:, are 

n·K::1B.a9,~: i·ri~:;y not n~:pre::_;,~:nt tK: opinion of interc:::::ntni.:,nt.j E:Xchi:~ngi.:,, 
Message 

From: Hester Serafini [Hester.Serafini@theice.com] 

Sent: 2/14/2019 9:42:48 AM 

To: Erik Haas [Erik.Haas@bakkt.com]; Trabue Bland [Trabue.Bland@theice.com]; Alex Albert [Alex.Albert@theice.com]; 

Donovan, Ei leen A. [/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; David Clifton 

[David.Clifton@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Beale, Joshua 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Beale, Joshua742]; Mohr, Julie 

A. [/O=CFTC/OU=Chicago/cn=Recipients/cn=jmohr] 

Subject: follow ups from our call yesterday 

Good morning. 

Thank you again for your time yesterday afternoon. I enjoyed the opportunity to discuss proposed changes to our BTC 

offering with you. This email covers the follow up items that I took away from our call. We look forward to continuing 

our discussion. 

Best regards, 

Hester 
--:;i ~ ;t ~t.:> ,(;,~=d ::ipji_:,nt of fri:":; ,,.,,,,,,,,,,,,,.,,,, 

rt. ;,h :~-i~h:._;:<>;•:•:h ~:~r 
Appointment 

From: Erik Haas [Erik.Haas@bakkt.com] 

Sent: 2/13/2019 9:42:33 AM 

To: Hester Serafini [Hester.Serafini@theice.com ]; Trabue Bland [Trabue.Bland@theice.com]; Alex Albert 

[Alex.Albert @theice.com]; Donovan, Eileen A. [/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN]; 

Bussey, Brian [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; David Clifton 

[David.Clifton@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Beale, Joshua 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Beale, Joshua742] 

Subject: CFTC/Bakkt/lCUS 

Location: Dial in below 

Start: 2/13/2019 4:00:00 PM 

End: 2/13/2019 5:00:00 PM 

Show Time As: Tentative 

Recurrence: (none) 

Continued conversation from 2/12 call including Hester Serafini. 

Internal extension: 8888 

Meeting ID: 6733# 

Password: i (b)(4) i 

Atlanta + 1 770 ·51·8 "8888 

Chicago +1 312 596 4412 

Houston +1 713 815 7276 

New York +1 212 896 2810 

San Mateo +1 650 581 5603 

Phoenix +1 480 444 0215 
Appointment 

From: Christina Canfield [Christina.Canfield@bakkt.com] 

Sent: 2/12/2019 1:32:33 PM 

To: Kelly Loeffler [Kelly.Loeffler@bakkt.com]; Trabue Bland [Trabue.Bland@theice.com]; Alex Albert 

[Alex.Albert@theice.com]; Erik Haas [Erik.Haas@bakkt.com]; Adam White [adam.white@bakkt.com]; David Clifton 

[David.Cl ifton@theice.com]; 'Geoffrey.Goldman@Shearman.com' [Geoffrey.Goldman@Shearman.com]; Bussey, 

Brian [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Reci pi ents/ cn=f973c0fe0387 42b4bb68c3eeae3f8171-Ku I kin, Matthew] 

CC: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Beale, Joshua 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOH F23SPDLT)/cn=Recipients/cn=Beale, Joshua742] 

Subject: Call: CFTC/Bakkt Discussion 

Location: Dial in below 

Start: 2/12/2019 4:00:00 PM 

End: 2/12/2019 5:00:00 PM 

Show Time As: Tentative 

Recurrence: (none) 

Internal extension: 8888 

Meeting ID: 4726# 

Password: i (b)(4) i 

Atlanta +1 770-618-8888 

Chicago +1 312 596 4412 

Houston +1 713 815 7276 

New York +1 212 896 2810 

San Mateo +1 650 581 5603 

Phoenix +1 480 444 0215 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/12/2019 11:29:24 AM 

To: Kulkin, Matthew [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Christina Canfield 

[Christina.Canfield@bakkt.com] 

CC: Bussey, Brian [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: Call: CFTC/Bakkt Discussion 

I think 1t defaults to 30 minutes. We should be fine to extend, but defer to Chdstina to check others schedule. 

From: Kulkin, Matthew [mailto:MKulkin@CFTC.gov] 

Sent: Tuesday, February 12, 2019 11:19 AM 

To: Christina Canfield <Christina.Canfield@bakkt.com> 

Cc: Trabue Bland <Trabue.Bland@theice.com>; Bussey, Brian <BBussey@CFTC.gov>; Thornton, Charlie 

<cthornton@CFTC.gov> 

Subject: RE: Call: CFTC/Bakkt Discussion 

WARNING - External email; exercise caution 

We may need more than 30 minutes···· is it possible to extend? 

-----Original Appointment-----

From: Christina Canfield [mailto:Christina.Canfield@bakkt.com] 

Sent: Tuesday, February 12, 2019 9:01 AM 

To: Christina Canfield; Kelly Loeffler; Trabue Bland; Alex Albert; Erik Haas; Adam White; David Clifton; 

Geoffrey.Goldman@Shearman.com; Bussey, Brian; Kulkin, Matthew; Thornton, Charlie; Donovan, Eileen A.; Smith, 

Thomas J.; Beale, Joshua; Bauer, Jennifer; Polley, Theodore; Sloan, Scott 

Subject: Call: CFTC/Bakkt Discussion 

When: Tuesday, February 12, 2019 4:00 PM-4:30 PM (UTC-05:00) Eastern Time (US & Canada). 

Where: Dial in below 

Internal extension: 8888 

Meeting ID: 4726# 

Password: !-·-·-{bj{4j"-·-·i 

Atlanta +1 770 618 8888 

Chicago +1 312 596 4412 

Houston +1 713 815 7276 

New York +1 212 896 2810 

San Mateo +1 650 581 5603 

Phoenix +1 480 444 0215 

Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/11/2019 4:05:07 PM 

To: Bussey, Brian [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Kulkin, Matthew 

[/o=CFTC/ou=Exchange Admin istrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =f973c0fe0387 42b4bb68c3eeae3 f8171-Ku I kin, Matthew] 

CC: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com]; Erik Haas [Erik.Haas@bakkt.com]; Hester Serafini [Hester.Serafini@theice.com] 

Subject: RE: FCM overview 

Sure---· lets use a dial in--

Dial-in: 

8888 (or external number below) 

Meeting ID: 4005# 

Passcode:i (b)(4) i L--·-·-·-·-·-·-·-·-·-·-·-· 

External numbers: 

Inside the US 

Atlanta 1-770-618-8888 

Chicago 1-312-596-4412 

Houston 1-713-815-7276 

New York 1-212-896-2810 

San Mateo 1-650-581-5603 

From: Bussey, Brian [mailto:BBussey@CFTC.gov] 

Sent: Monday, February 11, 2019 2:24 PM 

To: Trabue Bland <Trabue.Bland@theice.com>; Kulkin, Matthew <MKulkin@CFTC.gov> 

Cc: Thornton, Charlie <cthornton@CFTC.gov>; Alex Albert <Alex.Albert@theice.com>; Erik Haas 

<Erik.Haas@bakkt.com>; Hester Serafini <Hester.Serafini@theice.com> 

Subject: RE: FCM overview 

WARNING - External email; exercise caution 

Trabue, 

Thanks for this. Would you have time at 4:30 ET today to give some more detail on the below .. and how it fits with the 

FCM option? 

Thanks, 

Brian 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Monday, February 11, 2019 12:57 PM 

To: Kulkin, Matthew; Bussey, Brian 

Cc: Thornton, Charlie; Alex Albert; Erik Haas; Hester Serafini 

Subject: RE: FCM overview 

Matt, Brian and Charlie: 
From: Kulkin, Matthew [mailto:MKulkin@CFTC.gov] 

Sent: Saturday, February 09, 2019 8:08 AM 

To: Trabue Bland <Trabue.Bland@theice.com>; Bussey, Brian <BBussey@CFTC.gov> 

Cc: Thornton, Charlie <cthornton@CFTC.gov>; Kelly Loeffler <Kelly.Loeffler@bakkt.com>; Alex Albert 

<Alex.Albert@theice.com>; David Clifton <David.Clifton@theice.com> 

Subject: RE: FCM overview 

WARNING - External email; exercise caution 

Thanks Trabue. 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Friday, February 8, 2019 10:15 PM 

To: Bussey, Brian; Kulkin, Matthew 

Cc: Thornton, Charlie; Kelly Loeffler; Alex Albert; David Clifton 

Subject: FCM overview 

Matt, Brian, and Charlie: per our discussion today (sorry I had to get off) is a brief overview the FCM 

solution. Thank you again for your work on this. Please let me know if you have any questions. 

<:~,.;);~::::~\ .... :.; :.h;-> ''"""'""''"'' pj~:::~~~~e dehA~::: :t Hnd n::AW/ the ~~.enz:je:·, l rm~. rn::.::~:~~aq::.: n 2-:·J n(::~ :\:p:·~:::H.:nt th.: (::pink::n of jnk::::·::. •.-,•-;:---,::.~··, ❖·:) :·:·<t~>~:"'(;::.~.: ~::.-. 

net (:(::n~tH·ute 2.: ::.::(::n~r~~ct o:· JUt<:·~~~ ~e-~:. Unen(:ryptez:j ~::+:::ctrcnic n·i~~n i~~ net s~~:~~un~: Hnd th~::: : ~:dpient ::A thi~~ n-~~~:~~~~arv: is 

I -•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-•-

! 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/6/2019 5:06:51 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: About to call you w ith mike and others 

Great--212"748.4005 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Wednesday, February 06, 2019 5:03 PM 

To: Trabue Bland <Trabue.Bland@theice.com> 

Subject: About to call you with mike and others 

Importance: High 

WARNING - External email; exercise caution 

Which phone? 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/6/2019 11:00:00 AM 

To: Kulkin, Matthew [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =a2d0b8b95a0b46029f13ebead b 73f297-Bussey, Brian] 

Subject: RE: Call 

Hey--are you calling me or am I calling you'? 

-----Original Appointment-----

From: Kulkin, Matthew [mailto:MKulkin@CFTC.gov] 

Sent: None 

Subject: Call 

When: Wednesday, February 06, 2019 11:00 AM-11:30 AM America/New_York. 

Where: 

When: Wednesday, February 06, 2019, 11:00 AM to 11:30 AM. Eastern Time Where: 

unk~sB i.:,x~1!i::+\/ nok:d othet:.:\•'~:>e. if y::::u h~1\:,~: n~:i:~:>or-; to b::_:-l[e;,_,:,~: ynu Hi's~: 

i: i'-:'.·~•:>dJ.:..:'. ; , ~.~_::;/ ~ ::.>~ : (:'.); :::;:~::..:-; ,:. l.;;::._;. :):);: i;:.>: i \)," ;; ;t~_::: :..:.-,_.:~ :~i; ,::._;'., kd; ~: .c:..,.'.; i....,, \} ... :'., ; , ;...:.-
Appointment 

From: Kulkin, Matthew [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=F973COFE038742B4BB68C3EEAE3F8171-KULKIN, MATTHEW] 

Sent: 2/6/2019 10:31:23 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =a2d0b8b95a0b46029f13ebead b 73f297-Bussey, Brian]; Trabue Bia nd 

[Trabue.Bland@theice.com] 

Subject: Ca ll 

Attachments: invite.ics 

Start: 2/6/2019 11:00:00 AM 

End: 2/6/2019 11:30:00 AM 

Show Time As: Tentative 

Recurrence: (none) 

When: Wednesday, February 06, 2019, I 1:00 AM to 11:30 AM. Eastern Time 

Where: 
Appointment 

From: Kulkin, Matthew [MKulkin@CFTC.gov] 

To: Thornton, Charlie [cthornton@CFTC.gov]; Bussey, Brian [BBussey@CFTC.gov]; Trabue Bland 

[Trabue.Bland@theice.com] 

Subject: Ca ll 

Start: 2/6/2019 11:00:00 AM 

End: 2/6/2019 11:30:00 AM 

Show Time As: Tentative 

Recurrence: (none) 

When: Wednesday, February 06, 2019, 11:00 AM to 11:30 AM. Eastern Time 

Where: 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/6/2019 10:00:37 AM 

To: Kulkin, Matthew [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =a2d0b8b95a0b46029f13ebead b 73f297-Bussey, Brian]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: Trabue - are you free at 11 to compare notes? 

Sure--sounds good 

From: Kulkin, Matthew [mailto:MKulkin@CFTC.gov] 

Sent: Wednesday, February 06, 2019 9:34 AM 

To: Bussey, Brian <BBussey@CFTC.gov>; Trabue Bland <Trabue.Bland@theice.com>; Thornton, Charlie 

<cthornton@CFTC.gov> 

Subject: Trabue - are you free at 11 to compare notes? 

WARNING - External email; exercise caution 

Matthew Kulkin 

Director, Division of Swap Dealer & Intermediary Oversight 

U.S. Commodity Futures Trading Commission 

1155 21st Street, NW I Washington, DC 20581 I 0: 202.418.5213 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 2/5/2019 5:00:00 PM 

To: Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gill, Michael]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: FW: ICE submission on 2/1-Amendments to Rule 4.26 

WHAT"? I didn't even get a call? I try to build a market for one tiny contract: and I have to wait for the SEC? 

From: Jason Fusco 

Sent: Tuesday, February 05, 2019 1:55 PM 

To: Audrey Hirschfeld <Audrey.Hirschfeld@theice.com>; Mark Fabian <mark.fabian@theice.com>; Trabue Bland 

<Trabue.Bland@theice.com>; Tim Barry <Tim.Barry@Thelce.com> 

Subject: RE: ICE submission on 2/1-Amendments to Rule 4.26 

Spoke with Nancy and Amir, they communicated that Giancarlo would like us to withdraw the filing. Said both the SEC 

and CFTC are looking into the efficacy of speed bumps and don't believe this should be put through as a 10--day 

filing. They're looking for us to submit this for approval so there can be discussion with the industry. He mentioned our 

good working relationship and said the Chairman would approve a stay if we didn't pull it. 

FWIW .. they were not receptive to the fact there was no CI..OB activity in Daily Gold or Silver. 

From: Jason Fusco 

Sent: Monday, February 04, 2019 5:20 PM 

To: Audrey Hirschfeld <Audrey.Hirschfeld@theice.com>; Mark Fabian <mark.fabian@theice.com>; Trabue Bland 

<Trabue.Bland@theice.com> 

Subject: FW: ICE submission on 2/1-Amendments to Rule 4.26 

FYI - First inquiry from DMO about a rule filing in quite some time. 

From: Markowitz, Nancy [mailto:NMarkowitz@CFTC.gov] 

Sent: Monday, February 04, 2019 5:14 PM 

To: Jason Fusco <Jason.Fusco@theice.com> 

Cc: Zaidi, Amir <AZaidi@CFTC.gov> 

Subject: ICE submission on 2/1-Amendments to Rule 4.26 

WARNING - External email; exercise caution 

Hi Jason: 

Amir and I would like to have a call with you tomorrow to discuss ICE's rule certification regarding amendments to Rule 

4.26. We have availability any time after 1:30. Can you tell me a time convenient for you to talk. 

Thank you. 

Nancy Markowitz 

Deputy Director 

Market Review Branch 
Division of Market Oversight 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 12/19/2018 4:39:16 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: FW: 4(c) request 

1..01..--so how can I file? 

From: Sloan, Scott [mailto:SSloan@CFTC.gov] 

Sent: Wednesday, December 19, 2018 4:37 PM 

To: Trabue Bland <Trabue.Bland@theice.com>; Audrey Hirschfeld <Audrey.Hirschfeld@theice.com> 

Subject: 4(c) request 

WARNING - External email; exercise caution 

Trabue and Audrey, 

Do you have time tomorrow afternoon to discuss the draft 4(c) request? We will have a few additional comments. 3:30 

Eastern works best for us, but we can be a bit flexible. 

Thanks, 

Scott Sloan 

Special Counsel I Division of Clearing and Risk 

U.S. Commodity Futures Trading Commission 

525 W. Monroe St. I Suite 1100 I Chicago IL 60661 

(312) 596-0708 I ssloan@cftc.gov 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 12/14/2018 7:51:29 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: FW: CFTC 

FYI 

From: Elizabeth King <EEzabeth.King(d;theice.com> 

Date: Friday, Dec 14, 2018, 6:54 PM 

To: Scott Hill <scotthilViiHhcice.com>, Jeffrey Sprecher <kffrev.Sprccher(d.theicc.com>, Finbarr Hutcheson 

<Finbarr.Hutcheson(dtheice com>, Carolyn Van den Daelen <Carnlvn V;:mdenDaekn(dtheice com>, Trabue Bland 

<Trabue Bland:c,)theice.com>, Alex Albert <1\lex.1\lbert'atheice.com>, Charles Lindsay <Charles.Lindsav(dtheice.com> 

Subject: CFTC 

I just got a call from a very animated Brian Bussey and Bob Wasserman. Brian says that the Chairman is not at all happy 

that ICE is asking for this last minute approval of a rule change that David Bailey told Brian had been approved by the 

BOE weeks ago. He asked why we didn't file this earlier so that the Commission didn't have to take extraordinary 

action. Brian noted repeatedly that the Commissioners are not happy with ICE. But if we get them a 40.5 filing on 

Monday they can get it done by Thur. Is that possible? 

They also want to know whether we could change the rule to shorten the termination time period to 30 days only in 

circumstances where termination is necessary because it will be illegal (or something along those lines). But that would 

of course require the BOE to agree to that variation. 

A question: What is the package of rules approved by BOE and filed with the SEC in which this shortening of the 

termination deadline is included? 

Elizabeth K. King 

Chief Regulatory Officer, ICE 

General Counsel & Corporate Secretary, NYSE -------------------------------------------­ N:: +1 21~.656.24~5 I DC: +1 202.661 .89481 Mobj (b)(6) i 

e hza beth. k I ng@th e ice. com •---------------------------------------·-·" 

www.intercontinentalexchange.com I www.NYSE.com 

111111 

NYSE 

:.lpl~:::n~ ci th!~~ '""'··'·"'""""" pj~:::~~~~e dehA~::: :t Hnd n::AW/ the ~~-enz:j::.::·, Th~~~- rnes~~-a;F: n·~t::/ nc:i' :\~p=·~~:~~ent th.: ~;pi::k:::: ····{ ::.~r(•''~::--•,::.~··, ·:-.f :·:. <t ~>~:"'(;::.~, : ;::. .. 

(lCE). h~ ~~utr~.ldl~Hie~~ ~~ ❖ , :--> .. ~"' net tr::n~tH'ute t: ::.::r::n~t"~~ct ot qut:t\~nk~:::, Un::.:nctyph.:d dect:\H~ic n·i~~n i~~ not S(~:~~Uf{: and Jv: r,~:dpbnt ci thi~~ n·K:~~.~~w;n is 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 12/12/2018 3:56:39 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: FW: accounting questions from the CFTC 

Attachments: CFTCquestions121218.docx 

I thought you would flnd this funny. Why on earth would the CFTC care how we actually writing down accounting 

entries. Wow--

pj~:::~~~~e dehA~::: Hnd n::AJy the~~/):)()::.: . Th~~~- rnes~~.asF: n·~t::/ nc:i' :\~p=·~~:~~ent the (::pj~ :.,,~; ❖ ~.-, ~:..p:_/"'-'"•;:---,n-·, ·:d :·:·:<t~Yv:·\w, :r,::_::_ 

net tr::n~tH'ute t: ::.::r.::n~t'~~ct ot qut:Vi~nk~:::. Un::.:nctyph.:d dect:\)n:::.:: rn~~il i~~ net s~:::~~ure and Jv: r,~:~~ipl~:::nt ci thi~~ n·K:~~-~~w;n 
1. Where will revenues earned in relation to bitcoin activity be classified on the Income Statement 

ofICE Clear US? 

a. Please confirm that all revenue earned by ICE Clear US for BTC clearing 

transaction fees will be collected from clearing members in the form of USD. 

b. Please confirm if ICE Clear US will be responsible for the calculation and 

payment of fees (paid in BTC) to the miners. If this is not the case, what ICE 

entity will be responsible for this activity? 

2. Where would the fees owed to Bakkt be classified on the Income Statement and on the Balance 

Sheet? 

3. How will the accounting group keep track of what amount of revenue needs to be passed on to 

Bakkt? 

a. What reports will be used to account for this calculation? 

4. Who will be responsible for recording the pass thru revenues and expenses related to bitcoin 

activity? 

a. Who will review these entries? 

b. How often will these entries be recorded and reviewed? 

5. Will the revenues passed over to Bakkt be recorded as a non-cash transaction or will there be a 

physical movement of cash into a Bakkt bank account? 

6. Please provide an example of journal entries that will be recorded on the general ledger in order 

to recognize the revenues earned and owed to Bakkt. 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 10/25/2018 5:59:29 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: Crypto_slide_deck_v20_092818_CFTC (002).pptx 

Attachments: Crypto_slide_deck_v20_092818_CFTC (002).pptx 

FYI 

~ r:·). h:; ::~-~;b~~jdj:~lde~:; t ~ut s.,,->: k<~-~.:-~e ,:~ d:· ~1~b;d: ~:·c :'. Ur:f;:n:::~·typt~::d e~ec-t:\;r+: ff:i:dj l~:; not r;:}{;Ut\~ t:r:d n~:i;: r:i;:{;ip :nt of "tj 

-v::< tA:!~.-~.~~--~; ~): ,./V ;~.;t:: :~~-,:: i\:;-~:l :.~,:::~ d ~: -;~ d: ~ ~ \· : UH>~~- ::~ :'..; ~: c.~~ ~s~;c ,:::de~ i ~,::~,} nsk:~1 r:r; (/ C'.)tnrr:~;nk~i:(~on 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 10/25/2018 1:45:47 PM 

To: Gill, Michael [/o=CFTC/ou=Exchange Admin istrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gil l, Michael]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo] 

Subject: Re: Institutional markets gear up for OTC trading 

[ _____________________________________________________ N _o n _-Res _Po _n s iv e --------------------------------------------------___I 

On: 25 October 2018 13:29, "Gill, Michael" <Tv1GilLa>CfTC.gov> wrote: .-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-. 

i Non-Responsive i 

' ' j_·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·i 

From: Thornton, Charlie 

Sent: Thursday, October 25, 2018 9:29 AM 

To: Gill, Michael 

Subject: FW: Institutional markets gear up for OTC trading 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, October 25, 2018 9:01 AM 

To: Thornton, Charlie; Alex Albert; Fred Hatfield (External) 

Subject: Institutional markets gear up for OTC trading 

Let staff know that this is slipping away from the CFTC! https://wwwJorbes.corn/sites/astanley/2018/10/23/unchartedbitcoin-otc-markets-gear-up-for-institutional-inflows/amp/ 

Hope you had a good t rip. 

Trabue 

Trabue Bland 

President, ICE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street 40th Floor ' Telephone:_+1_ 770.9_16.7832 (Atlanta) I +1 212.748.4005 (New York) 

Mo bi I e: {__ ___________ ( b )( 6) __________ ___: 

trabue.b!and@theice.com 

intercontinentalexchange.com 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 10/23/2018 9:15:36 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: FW: FISMA staff analysis on CFTC Chair Giancarlo Wh ite Paper 

Attachments: FISMA staff analysis on CFTC Cha ir Giancarlo White Paper.docx 

In case you didn't get this. 

From: Tim Grange <Tim.Grange(a.:theice.com> 

Date: Tuesday, Oct 23, 2018, 9:14 AM 

To: **Regulatory and Legislative <R~_gulatorvandLegislativeraJThelce.com> 

Subject: FISMA staff analysis on CFTC Chair Giancarlo White Paper 

This is Patrick Pearson' s analysis/critique of the Giancarlo WP on which he will brief Member States today 

Tim 
DISCLAilvfER 

This document has been prepared by services to facilitate discussions. It cannot be 

understood as representing the Commission's position on these issues and does not bind 

the Commission in any way 

Brussels, 22/10/2018 

CFTC Chairman Giancarlo's White Paper "Cross-Border Swaps Regulation 

Version 2.0" 

DG FISMA staff internal analysis 

This staff analysis aims to give context to and reflect on CFTC Chairman C. Giancarlo's 

White Paper "Cross-Border Swaps Regulation Version 2.0. A Risk-Based Approach with 

Deference to Comparable Non-US. Regulation", as published on 1 October 20181

. 

The stated objectives of the White Paper are to pursue improvements to the CFTC's 

current regulation of derivatives activities in a cross-border context, while remaining in 

line with the 2009 G20 Pittsburgh reforms and in full accordance with the letter and spirit 

of Title VII of the Dodd-Frank Act2

. The goal is to 'adopt rulemakings that address 

systemic risk to the US. financial system in a ivay that is better tailored to the market as 

it exists nmv, not as it existed in 2010 or even in 2013' 3 

. 

These overall goals are welcomed as arrangements for cross-border regulation should 

keep pace with developments in international financial markets and the global regulatory 

environment and so adequately reflect important challenges that regulators face, in 

particular regarding the key objective of addressing systemic risk to safeguard the 

stability of the financial system. Similar to the CFTC's policy goals referred to in the 

White Paper, the European Commission has recently presented a legislative proposal 

('the EU legislative proposal') to revise the European Union's derivatives regulation to 

safeguard the financial stability of the Union as its prime objective 4. 

Current scope of the CFTC's supervisory framework 

The external reach of the CFTC is based on section 2(i) of the Commodity Exchange Act 

('CEA') which extends the CFTC' s authority to activities that "have a direct and 

significant connection with activities in, or effect on, commerce of the United States". For 

a number of years, the European Commission has consistently raised its concerns about 

the wide extra-territorial scope attached to this provision by the CFTC's Cross-Border 

Guidance, and in particular its definition of a 'U.S. person'. the European Commission 

1 https://www.cftc.gov/sites/default/files/2018-10/Whitepaper _ CBSRlO0 118.pdf 2 White Paper, Page 12 3 White Paper, Page 14 4 Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) No 

1095/2010 establishing a European Supervisory Authority (European Securities and Markets 

Authority) and amending Regulation (EU) No 648/2012 as regards the procedures and authorities 

involved for the authorisation of CCPs and requirements for the recognition of third-country CCPs. 

COM/2017/0331 final - 2017/0136 (COD) 
services therefore support the conclusion reached in the White Paper that, as a 

consequence of this wide scope, "global derivatives markets that involve a 'US. person' 

should adopt all CFTC trading rules, including rules that do little to reduce counterparty 

risk" 5

. The European Commission services take note of the comment in the White Paper 

that this approach is 'simply not sustainable and may signal to non-US. regulators that 

the CFTC does not respect their rightful sovereignty over entities established and 

operating in their jurisdictions '

6

. 

The "extraordinarily expansive "7 definition of 'U.S. person' in the CFTC Cross-Border 

Guidance has also been commented on by the G20 Financial Stability Board OTC 

Derivatives Regulators Group (ODRG).The CFTC interprets section 2(i) of CEA so that 

when a non-US person is a booking entity (i.e. the legal counterparty) to swaps and even 

if the US branch, agency, affiliate, or subsidiary of a non-US. person engages in 

solicitation or negotiation in connection with the swap entered into by the non-US. 

person, the CFTC applies the Dodd-Frank Act requirements, including the registration 

requirement, for swap dealers also to the non-US. person. The ODRG noted, inter alia, 

that the continued inclusion of subsidiaries (' affiliates') in the scope of the definition of a 

'US Person' contributed significantly to the extra-territorial effect of the provision and 

the consequential application of CFTC rules and regulations in foreign jurisdictions. 

Focus on systemic risk 

When suggesting ways to limit the current extra-territorial effect of its regulatory and 

supervisory approach, the White Paper also suggests that in the future 'the focus should 

be on how best to prevent systemic risk created outside the United States ft·om returning 

to the United States' 8

. Considering "cross-border risk transfer" would determine "the 

necessity of applying CFTC swaps rules extraterritorially '', which would be consistent 

with the requirement for the CFTC to focus on activities outside the United States that 

have a "direct and significant" connection with the United States9

. 

The CFTC's prime focus would therefore be on preventing external ::;ystemic risk from 

entering the US. In the view of the European Commission services, this is a more 

appropriate approach which, in theory, would also permit a greater degree of 

proportionality in addition to reducing extra-territoriality. The White Paper also identifies 

measures to mitigate systemic risk that has a 'direct and significant' impact on the US. 

These measures include mandatory clearing of derivatives in CCPs, margin collateral for 

uncleared derivatives, capital, and ensuring that sufficient information is available for 

effective supervision and oversight through record keeping and regulatory reporting. 10 . 

However, in addition to the territorial scope, the decisive factor is how the CFTC would 

seek to apply those measures in practice. 

5 White Paper, Page 22 6 White Paper, Page 20 7 White Paper, Page 15 8 White Paper, Page 22 (underline European Commission) 9 White Paper, Page 22 1 0 White Paper, Page 21 

2 
Systemically important vs non-systemically important non-US CCPs 

With regard to non-US CCPs, the White Paper suggests to distinguish in general between 

those CCPs that pose systemic risk to the US financial system and those that do not 

present such risk. The White Paper suggests to "expand the use of CFTC 's exemptive 

authority for non-US. CCPs that are subject to comparable regulation in their home 

country and do not pose substantial risk to the US. financial ~ystem, permitting them to 

provide clearing services to US. customers indirectly through non-US. clearing 

members that are not registered with the CFTC" 11 . 

Non-systemically important non-US CCPs 

Title VII of the Dodd-Frank Act permits the CFTC to exempt a non-US. CCP from 

registration for the clearing of derivatives if the CFTC determines that the CCP is subject 

to "comparable, comprehensive supervision and regulation" by appropriate government 

authorities in the CCP's home country 12. The CFTC applies this to non-US CCPs that do 

not pose systemic risk to the US. To date the CFTC has applied this approach to only 

four non-US CCPs 13 . In the White Paper, the CFTC describes the approach as an 

"outcomes based approach (that) reflects the CFTC 's recognition that a non-US. 

jurisdiction's supervis01y and regulatory scheme applicable to its CCPs may d?fferfrom 

the CFTC 's in certain re~pects, but nevertheless may achieve the same underlying goals. 

This approach also supports the CFTC 's effort to strike an appropriate balance by 

focusing on the risk implications to the United States, while promoting global 

harmonization14 . 

The CFTC is currently proposing to adopt regulations that would codify the staff policies 

and procedures that the CFTC is currently following with respect to granting exemptions 

from CCP registration for non-systemically important non-US CCPs15 . The proposed key 

conditions for an exemption from registration with the CFTC are as follows. 

The supervisory and regulatory framework of a home country adheres to the 

CPMI IOSCO Principles for Financial Market Infrastructures (PFMis) and 

achieves outcomes that are comparable to that of the supervisory and regulatory 

requirements applicable to registered US CCPs16 . 

11 White Paper, Page iv 12 Section 5b(h) of the CEA, 7 U.S.C. § 7a-l(h). 13 Japan Securities Clearing Corporation; Korea Exchange; OTC Clearing Hong Kong Limited; ASX Clear 

(Futures) Pty Limited 14 White Paper, Page 45 15 See Exemption From Derivatives Clearing Organization Registration, 83 FR 39923 (Aug. 13, 2018): 

https://www.f:,>po.gov/fdsys/pkg/FR-2018-08-13/pdf/201817335.pdf. Notice of Proposed Rulemaking 

published on 18 August 2018 and open for comments until 10 October 2018. 16 Proposed Ref:,'Ulation 39.6(a)(l)(i-ii) 

3 
A memorandum of understanding (MOU) must be in effect between the CFTC 

and the non-US CCP's home country regulator. The home country supervisor 

must agree, inter alia, to provide to the CFTC any information that the CFTC 

deems necessary to evaluate the non-US CCP' s initial and continued eligibility 

for exemption or to review compliance with any conditions for the exemption 1

7 

. 

Importantly, however, an exempt non-US CCP must also meet many further 

requirements, inter alia: 

consent to jurisdiction in the United States and designate an agent in the United 

States, for notice or service of process, pleadings, or other documents issued by or 

on behalf of the Commission or the U.S. Department of Justice in connection 

with any actions or proceedings against, or any investigations relating to, the 

exempt non-US CCP or any U.S. person or Futures Commission Merchant 

('FCM') that is a clearing member or that clears swaps through an affiliated 

. b 1s c 1 eanng mem er ; 

comply and demonstrate ongoing compliance to the CFTC, with any condition for · exempt10n 19 . 

make all documents, books, records, reports, and other information related to its 

operation as an exempt non-US CCP (books and records) open to inspection and 

copying by any CFTC representative, and to promptly make its books and records 

available and provide them directly to CFTC representatives upon request20 ; 

provide an annual certification that it continues to observe the PFMis in all 

. 1 matena respects 21 ; 

meet reporting requirements (similar to the existing reporting requirements for 

exempt US CCPs) and provide directly to the CFTC - not via the home country 

supervisor - a report as of the end of each trading day: (A) Initial margin 

requirements and initial margin on deposit for each U.S. person; (B) daily 

variation margin, separately listing the mark-to-market amount collected from or 

paid to each U.S. person. (If a clearing member margins on a portfolio basis its 

own positions and the positions of its affiliates, and either the clearing member or 

any of its affiliates is a U.S. person, the exempt CCP must report initial margin 

requirements and initial margin on deposit for all such positions on a combined 

basis for each such clearing member and to separately list the mark- to-market 

amount collected from or paid to each such clearing member, on a combined 

basis). The CFTC notes that these requirements for exempt CCPs are similar to 

those for fully registered CCPs in Regulation 39.l9(c)(l). "lhese reports would 

provide the CFIC with information ... to assess the extent to which US. business 

is being cleared by each exempt DCO" 22; 

report as of the last day of each fiscal quarter, and submit the report to the CFTC, 

containing: (A) The aggregate clearing volume of U.S. persons during the fiscal 

quarter, and (B) the average open interest of U.S. persons during the fiscal 

quarter. If a clearing member is not a U.S. person, the data must include the 

transactions and positions of affiliates that are U.S. persons. 23 

17 Proposed Regulation 39.6(a)(2) 18 Proposed Ref:,'Ulation 39.6(b )(3) 19 Proposed Regulation 39.6(b)(4) 20 Proposed Ref:,1Ulation 39.6(b)(5) 21 Proposed Ref:,'Ulation 39 .6(b )(6) 22 Proposed Ref:,'Ulation 39.6(c)(2)(i) 23 Proposed Ref:,'Ulation 39.6(c)(2)(ii) 

4 
It is important to compare the CFTC's approach to non-systemically important CCPs as 

suggested in the White Paper and presented in the notice of proposed rulemaking in 

August 2018 with the EU legislative proposal of June 2017 to amend and improve the 

EU's supervisory arrangements for third country CCPs ('EMIR 2.2'). According to the 

EU legislative proposal - and also under the present Regulation - the regulation and 

supervision of CCPs a third country must be determined to be equivalent to that in the 

EU. The European Commission has adopted, to date, 16 equivalence decisions24 . When 

adopting these equivalence decisions the European Commission has for many years 

applied a broad outcomes-based assessment that the third country pursues broadly similar 

objectives regarding CCP supervision and regulation and explicitly considers the 

implementation of the CPMI-IOSCO Principles for Financial Market Infrastructures. 25 

This is similar to the approach suggested by the CFTC and that the CFTC now proposes 

to clarify in its regulations. 

Also similar to the CFTC's approach for non-systemically important CCPs, the EU 

requires the conclusion of a memorandum of understanding (MOU) between EU 

regulators - the European Securities Markets Authority, ESMA - and the third country's 

home supervisor regarding exchange of information and cooperation. 

The key difference between the EU' s current and proposed legislative approach, 

however, and the CFTC's current practice and proposed rules, is that, in the EU, a nonsystemically important third country CCP is not required to consent to EU jurisdiction, 

make documents, books, records, reports, and other information available for inspection, 

or report directly to ESMA and meet onerous, voluminous and extremely detailed 

reporting requirements for margins and positions etc. on a daily, weekly, monthly and 

annual basis. On this basis, it is therefore not clear to the European Commission services 

the extent to which the proposals in the CFTC White Paper would effectively reduce the 

extra-territorial effects of US rules 

Systemically important CCPs 

Regarding non-US CCPs and 'how best to prevent systemic risk created outside the 

United States from returning to the United States' 27, the CFTC' s White Paper states that 

"non-US. CCPs that clear swaps for US. persons and are deemed by the CFTC to pose 

substantial risk .specific to the US. financial system would continue to be required to 

register with, and be regulated by, the CFlC. These CCPs would be regulated and 

supervised as they are today with the CFTC 's regulatory and supervisory focus 

concentrated on the CCP 's US.-:facing clearing activity while recognizing the 

supervisory primacy of the home country regulator" 

24 Hong Kong, Australia, Japan (financial derivatives and commodities), Dubai, United Arab Elnirates, 

Mexico, Republic of Korea, Brazil, New Zealand, South Africa, Singapore, Switzerland, Canada, India 

and the USA (CFTC) https://ec.europa.eu/info/sites/info/files/emir-equivalence-decisions_ en.pdf 25 See e.g. European Commission Implementing Decision of 13 November 2015 on the equivalence of the 

Republic of Korea (EU) 2015/20385. 26 Commission proposal Art 25 (7) 27 White Paper, Page 22 (underline European Commission) 

5 
The White Paper also points out that systemic risk measures should be appropriately 

comparable across borders to mitigate the risk of cross-border contagion. "Accordingly, 

with respect to si,vaps reforms designed to mitigate systemic risk, the CFTC 's jurisdiction 

should continue to apply cross-border to U.S. firms on an "entity" basis, with the 

availability of substituted compliance for non-US. jurisdictions that are strictly 

comparable "

28 . Currently, five non-US CCPs are registered with the CFTC as DCOs29. 

They are considered to "have sign?ficant U.S. activity and thus could present systemic 

risk to the US. markets"30 . As registered DCOs, they may conduct both customer and 

proprietary clearing for U.S. persons. 

While the White Paper refers to the availability of substituted compliance for non-US 

jurisdictions that are strictly comparable, the European Commission services interpret the 

suggested policy approach to mean that there will be no exemption from the CFTC's 

authority for non-US CCPs if (a) they are of systemic importance to the US financial 

system and (b) if any U.S. clearing member of the non-US. CCP ('Futures Commission 

Merchant' FCM) is involved in a cleared trade. 

Regarding (b ), the European Commission services' understanding is that if a non-US 

CCP intends to provide clearing services to US FCMs it would continue to be considered 

as posing substantial risk to the US financial system. The issue is then which challenges 

non-US clearing members would face to provide services to US customers? It is the 

European Commission services' understanding that EU CCPs would in any event need to 

register with the CFTC, without benefiting from any exemptions and would continue to 

be fully subject to CFTC rules and regulations and be regulated and supervised as they 

are today. Furthermore, the CPMI-IOSCO Principles for Financial Market 

Infrastructures, require that CCPs should be supervised holistically as a group. This 

means that an EU CCP offering both exempted and non-exempted services would 

continue to be subject to the (stricter) regulatory and supervisory regime on the part of 

the CFTC. Subject to further clarification, it would therefore appear that for most if not 

all EU CCPs the approach suggested in the White Paper would not introduce a significant 

change from the current approach. 

Regarding (a), the EU legislative proposal recognises the concerns identified in the 

CFTC White Paper. The regulation of derivatives activities should take into account (i) 

cross-border systemic risk, (ii) whether jurisdictions should have measures in place to 

mitigate systemic risk arising from the activities of entities from outside their 

jurisdiction, and (iii) deference should be available for comparable jurisdictions. 

However, in respect of non-systemic CCPs, the EU legislative proposal contains the 

following important differences for the regulation of systemically important third country 

entities. 

The EU legislative proposal categorises third-country 'systemically important' and 'nonsystemically important' CCPs according to specific criteria. These include: 

28 White Paper, Page 22 29 EUREX, ICE UK, LCH UK, LCH SA, Singapore. ICE Canada is also registered to clear futures on 

energy products. 30 White Paper, p. 36 

6 
the nature, size and complexity of the CP, including the aggregate value of 

transactions cleared; 

- the aggregate exposure of the CCP engaged in clearing activities; 

- the effect on EU financial stability that its interdependencies and relationships with 

other financial market infrastructures, other financial institutions entities may have; 

- the effect that its failure may have on financial markets, institutions, the broader 

financial system of the European Union; 

- its clearing membership structure31 . 

These criteria will be subject to further technical elaboration so as to ensure a consistent 

and coherent application in practice32. 

The US Financial Stability Oversight Council (FSOC) designates those financial market 

utilities or payment, clearing, or settlement activities that the Council determines are, or 

are likely to become, systemically important. In making that determination, the FSOC 

takes into account the following33 : 

"(AJ The aggregate monetary value of transactions processed by the financial market 

utility or carried out through the payment, clearing, or settlement activity. 

(BJ The aggregate exposure of the .financial market utility or a .financial institution 

engaged in payment, clearing, or settlement activities to its counterparties. 

(CJ The relationship, interdependencies, or other interactions of the financial market 

utility or payment, clearing, or settlement activity with other financial market utilities 

or payment, clearing, or settlement activities. 

(DJ The effect that the failure of or a disruption to the financial market utility or 

payment, clearing, or settlement activity would have on critical markets, financial 

institutions, or the broader financial system. 

(EJ Any other factors that the Council deems appropriate". 

This categorisation in the EU legislation brings legal clarity, transparency for market 

operators and a focused regulatory and supervisory regime. The regulatory and 

supervisory measures that this new EU regime will introduce for third-country CCPs that 

are of importance for stability of the EU financial system are targeted. Compared to, and 

in some instances inspired by, the CFTC regulatory and supervisory approach and 

measures they are: 

similar to the CFTC, after recognition a systemically important third-country 

CCP providing clearing services in the European Union must comply on an 

ongoing basis with core prudential and oversight requirements34 (subject to 

substituted compliance and deference, see below) ; 

similar to the CFTC, after recognition a systemically important third-country 

CCP providing clearing services in the European Union must conclude an 

effective MoU; 

similar to the CFTC, after recognition a systemically important third-country 

CCP providing clearing services in the European Union must provide any 

necessary information directly to ESMA. The EU legislative proposal would 

permit ESMA to seek full access to information as well as investigation powers 

over the third-country CCPs under its supervision. This is an important 

improvement over the very limited access it currently has. The need for such 

31 Commission proposal Art. 25 (2a) 32 Ibid. 33 12 U.S. Code§ 5463 - Designation of systemic importance 34 EU legislative proposal Art 25 (2b) (a) 

7 
information to be provided by systemically important third-country CCPs is 

comparable to the powers the CFTC currently enjoys in seeking that information; 

similar to the CFTC, after recognition a systemically important third-country 

CCP providing clearing services in the European Union ESMA should be able to 

conduct on-site inspections in third-country CCPs. "Such examinations focus 

primarily on the DCO 's services on behalf of US. clearing firms and are 

conducted in full coordination with the home country supervisor. This approach 

allows the CFTC to exercise its authority over US. businesses without impinging 

on the non-US. DCO 's home country regulator's role as the primary regulator of 

the DCO "

35 . Like the CFTC, after full notification examinations should focus 

primarily on the CCP' s services on behalf of EU clearing members and are to be 

conducted in full coordination with the home country supervisor. ESMA should 

rely fully on the home country regulator in the case of most other CCPs36 

Supervision of systemically important CCPs 

The White Paper states that "Even where registration or regulation of non-US. entities 

may be required, the CFTC should endeavor to work cooperatively with other regulators 

in order to achieve common regulatory goals such that the actual effect of being 

registered or regulated is still based on deference. To make this lt'ork and ensure access 

to iriformation regarding market participants that have a nexus to the United States, the 

CFTC should continue the practice of entering into memoranda of understanding 

(MOUs) with the relevant home count1y regulators to provide a framework for the 

sharing of information regarding entities relying on a substituted compliance 

determination. 37 ESMA is fully expected to exercise its authority over EU business 

without impinging on a non-EU CCP home country regulator's authority in exactly the 

same manner as the CFTC describes that role for itself 

The main differences appear to relate to the involvement of central banks and to the 

degree of 'deference' offered. 

Central bank involvement 

Concerning the involvement of central banks in the EU legislative proposal, this is a 

direct and logical consequence of focusing on financial stability and its connection with 

monetary policy. Liquidity, margins and collateral are all narrowly linked. To be precise, 

CCP margins mitigate credit risk. Margins are provided by collateral and margins and 

collateral can create liquidity stress in markets. Furthermore, collateral value haircuts can 

create liquidity stress. CCPs can hold collateral to secure liquidity facilities at the central 

35 White Paper PP36-37 36 EU legislative proposal Art 25e 37 White Paper P32. 

8 
bank. As overseers of payment systems through which liquidity and collateral is 

channelled and as liquidity providers, central banks have an important role to fulfil in 

respect of CCPs. These issues are also reflected in international standards (CPMI-IOSCO 

PFMis mentioned above)3 8

. In the European Union, the responsibility for these areas and 

financial stability in general does not fall under the statutory responsibilities of financial 

market authorities. It belongs to the authority of central banks. The EU legislative 

proposal reflects this authority. 

Substituted compliance and deference 

Regarding 'substituted compliance' and 'deference', the White Paper states that the 

CFTC "currently shows insufficient deference to non-US. regulators that have adopted 

comparable swaps reforms for their jurisdictions and is inconsistent with the CFTC 's 

traditional approach of comity with competent non-US. regulators in futures 

regulation39. Furthermore that "The CFTC should operate on the basis of comiz, not 

un{formity, with non-US. regulators that oversee comparable regulatory regimes" 0

. 

The European Union's legal and policy instrument in this area is by means of adopting 

equivalence decisions. These decisions relate to the regulatory and supervisory system of 

a country (not an individual CCP entity). The White Paper states that "Substituted 

compliance ... is broadly similar to the concept of "equivalence'' in the EU''. 41 This 

however overlooks important differences and does not reflect the legal and practical 

distinction between the two approaches. 

The European Commission services understand the possible miscomprehension that may 

have arisen in this field. In order to address this shortcoming in EU derivatives regulation 

which has not benefitted from a system based on 'substituted compliance' for firms as 

applied by the CFTC, the EU legislative proposal would introduce exactly such a system 

(called 'comparable compliance')42

. Having witnessed the CFTC's positive experience in 

applying 'substituted compliance' for individual firms, the EU legislative proposal 

intends to replicate the essential elements, adjusted where appropriate, in the EU's 

regulatory approach to third-country CCPs. In this light, the statement in the White Paper 

that "The application of EU law to US. financial markets without deference to the CFTC 

is unacceptable43 

" seems to be based on a misreading of the EU legislative proposal. 

38 PFMI Principles 3, 4-6, 20 39 White Paper P 16 40 White Paper P 24 41 White PaperP29 42 EU Le,gislative proposal Art 25a 43 White Paper P 42 

9 
The cross-border relationship between the European Union and the US is determined by 

and subject to the European Commission's 2016 equivalence decision for the US 

CFTC44 . This decision grants full equivalence to the US CFTC's regulatory and 

supervisory system, with three specific exceptions relating to risk management standards 

(calculating clearing members' proprietary positions on a liquidation period two days net 

basis; the absence of anti-pro-cyclicality measures; and measures to withstand the default 

of the two largest clearing members). With these exceptions, and by granting 

equivalence, the European Union defers completely to the regulation and supervision of 

US CCPs by the CFTC and, as explained in the paragraph above, in practice means that 

the CFTC's rules and jurisdiction apply. The European Commission must undertake 

regular reviews of the equivalence decision and may undertake a specific review at any 

time if relevant developments arise or the conditions for the decision are no longer met45 . 

The EU has a long and positive experience in the field of 'deference' and has applied the 

principle since 1978. It is a fundamental principle of the European Union's legal order 4

6

. 

It considers this the correct manner of applying the principle of international comity. 

The White Paper states that: "Mutual commitment to cross-border regulatory deference 

means that market participants can rely on one set of rules - in their totality - without 

fear that another jurisdiction will seek to selectively impose an additional layer of 

regulatory obligations"47 . In view of the above, this can only be supported. In practice, 

however, the European Union has experienced a degree of disequilibrium between the 

degree of deference offered to US CFTC and what it has been able to benefit from in 

return. The US CFTC has granted a relatively limited degree of 'substituted compliance' 

to EU CCPs. The CFTC in 2016, determined to provide "limited and enumerated relief 

from the application of Commission regulations to discrete aspects of a DCOICCP 's 

non-US. clearing activities, subject to restrictions"48 . With the limited degree of 

substituted compliance granted by the CFTC to the EU in 2016, any improvement in 

granting full deference to any jurisdiction outside of the US can only be fully supported. 

44 COM1v1ISSION IMPLEMENTING DECISION (EU) 2016/377 of 15 March 2016 on the equivalence of 

the regulatory framework of the United States of America for central counterparties that are authorised 

and supervised by the Commodity Futures Trading Commission to the requirements of Regulation 

(EU) No 648/2012 of the European Parlian1ent and of the Council 45 For example, a fundamental criterion for granting equivalence to the US CFTC is that it has in place an 

effective equivalent system for the recognition of EU CCPs. If developments arose that made it 

challen,ging for EU CCPs to continue to effectively operate on the markets regulated by the CFTC this 

would oblige the European Commission to re-assess the equivalence granted by the Decision and 

possibly repeal its legal act. 46 Case 120/78, Rewe-Zentrale AG v Bundesmonopolverwaltung fur Branntwein [1979] ECR 649 47 White Paper P 31 48 CFTC Letter No. 16-26 No-Action March 16, 2016 Division of Clearing and Risk 

10 
Outcomes-based decisions 

The European Commission services also support the CFTC's suggestions to adopt a more 

outcomes-based approach than in the past. "Regrettably, the way in which the CFTC has 

conducted its substituted compliance analysis of swaps reform in the past is one of 

granular, rule-by-rule comparison, regardless of the type of requirement that is the 

su~ject ~f the substituted compliance determination". The European Commission has 

never applied a line-by-line comparison of third-country rules. The European 

Commission services suggest that, if the CFTC abandons this practice, it should be 

combined with offering complete deference to other jurisdictions rather the limited 

degree that has been offered resulting from its granular approach. 

Stricter substituted compliance.for systemic risk requirements 

The White Paper furthermore states that 'The CFTC should ... seek stricter comparability 

for substituted compliance for requirements intended to address systemic risk and more 

flexible comparability for substituted compliance for requirements intended to address 

market and trading practices49. These requirements would in particular apply for 

reporting requirements: "Regulat01y reporting is an example of a requirement that is 

important to addressing ::;ystemic risk, given the critical role that regulat01y reporting 

plays in helping agencies monitor the build-up of systemic risk. For this reason, before 

the CFTC would grant substituted compliance with respect to regulatory reporting, the 

non-US. jurisdiction should show a high degree of comparability with respect to 

applicable data reporting field<,, including use cif entity identifiers, product identifiers, 

transaction identifiers, and critical data elements "

50. 

Subject to further clarification, the European Commission services are concerned that 

this may mean that (a) EU CCPs will not only continue to be subject to heavy US 

supervisory and reporting requirements, but would be subject to further increased 

requirements and (b) the CFTC will provide less deference than is offered today. The 

White Paper notes that "A criticism of the CFTC 's current cross-border approach is that 

the CFTC has limited data regarding the non-US. swaps operations of US-based 

entities, unless they receive a US. affiliate guarantee51 . The European Commission 

services note that the criticism that it has received from EU firms is not that the CFTC 

requests too little information but that it requests an excessive amount of information by 

seeking access to the entire books and records of non-US swap dealers irrespectively of 

whether there is a link with the US business. 

Non-U.S. Trading Venues 

The White Paper proposes to end the bifurcation of the global swaps markets into 

separate U.S. person and non-US. person marketplaces. The European Commission 

services welcome the proposal to exempt non-US. trading venues from the need to 

registers with the CFTC as a swap execution facility when the host jurisdiction has 

49 White Paper Principle 5 50 White Paper P 31 51 White Paper P 63 

11 
adopted comparable G20 swaps reforms. This approach follows the approach pursued in 

the CFTC exemption order of December 2017 for EU multilateral and organised trading 

facilities and both the EU and the US should pursue a similar approach with respect to 

other jurisdictions that have put in place swap execution reforms. 

Non-U.S. Swap Dealers 

The White Paper advocates a continued requirement that non-US. swap dealers whose 

swap dealing activity poses a "direct and significant" risk to the U.S. financial system 

register with the CFTC. The Commission services welcome that fact that these 

registrations show appropriate deference to non-US. regulatory regimes that have 

comparable requirements for entities engaged in swap dealing activity. However, 

confirmation that this is the case for investment firms that are authorised under the EU's 

MifiD regime would be required. 

Under CFTC regulations, a person is deemed to be a swap dealer as a result of its swap 

dealing activity it: during the preceding twelve months, the aggregate gross notional 

amount of the swap dealing exceeds the de minimis threshold. When swap transactions 

have cross-border aspects, it is necessary to determine whether the swap dealing activity 

has a "direct and significant" effect on the U.S. financial system and therefore should 

count toward the de minimis threshold. The European Commission services understand 

that all non-US. dealers should be permitted to exclude from their de minimis threshold 

those swaps that are executed on a registered or exempt SEF, DCM, or FBOT and 

cleared by a registered or exempt clearing organization, even if the dealing activity 

involves U.S. persons. Confirmation that this permission would include all swaps 

executed by non-US. dealers on MiflD-regulated multilateral or organised trading 

facilities would be required. 

ANE Transactions 

The White Paper appears to take a territorial approach to U.S. swaps trading activity, 

including trades that are "arranged, negotiated, or executed" within the United States by 

personnel or agents of such non-US. persons. So-called "non-incidental swaps trading" 

that takes place in the United States should be subject to CFTC swaps trading rules. The 

White Paper describes ANE Transactions as swap transactions by non-US. 

counterparties that are "arranged, negotiated, or executed" within the United States by 

personnel or agents of a non-US. person located in the United States. The White Paper 

proposes that, should a swap be executed in the United States (the "E" in "ANE 

Transaction"), then the counterparties should be required to follow U.S. swap execution 

rules. On the other hand, the White Paper describes ANE Transactions as, by definition, 

transactions between non-US. persons that do not pose systemic risk to the U.S. 

financial system merely by virtue of being arranged, negotiated, or executed within the 

United States. In light of these circumstances, the White Paper proposes that ANE 

Transactions should not count toward a potential non-US. dealer's de minimis threshold 

if the non-U. S. dealer is in a Comparable Jurisdiction. In this context, clarification that 

this proposal implies that a MiFID authorised investment firm can transact with a nonUS person on a SEF without this transaction being counted against the de minimis 

threshold would be required. 

12 
------------ -----

Deference ? 

- ---

ANNEXA 

Section 

Subpart A - General Provisions Applicable to Derivatives Clearing 

Organizations 

Section 39 .1 - Scope. 

Section 39.2 - Definitions. 

Section 39.3 - Procedures for registration. 

Section 39.4 - Procedures for implementing derivatives clearing 

organization rules and clearing new products. 

Section 39.5 - Review of swaps for Commission determination on 

clearing requirement. 

Section 39. 6 - /Reserved] 

Section 39.7 - Enforceability. 

Section 39.8 - Fraud in connection with the clearing of transactions on 

a derivatives clearing organization. 

Section 39.9 - Scope. 

Subpart B - Compliance with Core Principles 

Section 39 .10 - Compliance with core principles. 

Section 39 .11 - Financial resources. 

Section 39 .12 - Participant and product eligibility. 

Section 39.13 - Risk management. 

Section 39.14 - Settlement procedures. 

Section 39.15 - Treatment of funds. 

Section 39 .16 - Default rules and procedures. 

Section 39.17 - Rule enforcement. 

Section 39.18 - System safeguards. 

Section 39 .19 - Reporting. 

Section 39.20 - Recordkeeping. 

Section 39.21 - Public information. 

Section 39.22 - Information sharing. 

Section 39.23 - Antitrust considerations. 

Section 39.24-39.26 - [Reserved] 

Section 39.27 - Legal risk considerations 

Relief -

INo deference 

No deference 

No deference 

INo deference 

INo deference 

IN/A 

INo deference 

No deference 

INo deference 

IFRS allowed 

INo deference 

0 artial 

deference 

limited 

application of 

39.12 (b)(6). 

39.12(a)(2)(iii) 

and 

39.13(h)(5) 

Daftial 

deference 

No deference 

Daftial 

deference 

No deference 

INo deference 

INo deference IFRS allowed 

INo deference 

INo deference 

INo deference 

INo deference 

IN/A 

No deference 

13 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 10/22/2018 4:18:44 PM 

To: Trabue Bland [Trabue.Bland@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: Re: Bakkt Bitcoin (USD) Daily Futures Contract to Begin Trading on December 12, 2018 

Thanks. 

On: 22 October 2018 15:46, "Trabue Bland" <Trabue.Bland@theice.com> wrote: 

I am sure someone at the CFTC will see this-just FYI, this is just to get the ISV s etc to schedule it-basically 

to put in placeholder. CFTC staff should know this, but judging by the surprising number of emails I have 

received from various industry folks, you never know. 

Trabue Bland 

President 

ICE Futures US 

Phone 212.748.4005 Cell 404.786.4082 

From: Intercontinental Exchange (ICE) <ICE@theice.com> 

Date: Monday, Oct 22, 2018, 3:05 PM 

To: Trabue Bland <Trahue.BlandCqJtheice.com> 

Subject: Bakkt Bitcoin (USD) Daily Futures Contract to Begin Trading on December 12, 2018 

View as webpage. 

BAKKTTM BITCOIN (USD) DAILY FUTURES CONTRACT 

TO BEGIN TRADING ON DECEMBER 12, 2018 

22 OCTOBER 2018 

ICE Futures U.S., Inc. will list the new Bakkt Bitcoin (USD) Daily Futures Contract tortrnding on Wednesday, December 

12, 2orn 1

• The Bakkt Bitcoin (USO) Daily Futures Contract is a physically-settled daily futures contract for bitcoin held in 

Bakkt LLC, ICE's Digital Asset Warehouse, and will be cleared by ICE Clear US, Inc. 

LJ 

• ..:: •• t:.c;:;: • .-::. I r.r/·.··.······· 

-

R -
Subscription Center 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 10/16/2018 11:40:56 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: FW: call 

See they are not working with us anymore- I am not sure what to do 

From: Hester Serafini <Hester.Serafini@theice.com> 

Date: Tuesday, Oct 16, 2018, 10:33 AM 

To: Trabue Bland <Trabue.Bland@theice.com> 

Subject: FW: call 

From: Julie Mohr (External) 

Sent: Tuesday, October 16, 2018 11 :30 AM 

To: Hester Serafini; Donovan, Eileen A. 

Subject: Re: call 

WARNING - External email; exercise caution 

Hi Hester, 

We would be happy to have a call to discuss any concerns with the 40.5 draft rule filing. However in 

order to give ICUS a fulsome discussion of all potential issues, we need more time in order to complete 

our review of all materials that were sent on Friday. 

I would like to suggest a call on Tuesday of next week. Is ICUS staff available for a discussion on Tuesday 

or is there a different day that would be better? 

Julie 

-------- Original Message--------

From: Hester Serafini <Hester.Serafini@theice.com> 

Date: Tue, October 16, 2018 9:09 AM -0500 

To: "Mohr, Julie A." <JMohr@CFTC.gov> 

Subject: call 

Hi Julie, 
We received a call from Charlie at the CFTC and were informed that some changes need to be made to 

our draft filing. Specifically we were told that OCR wants us to follow 40.5 (a) 5 more strictly. Would you 

have time for a call tomorrow to discuss what specifically you are looking for. That would be very helpful 

to us as we could use your guidance regarding what is missing in our current draft. Thank you very much 

in advance for your time. 

Hester 

Hester Serafini 

President and COO of ICE Clear US 

Intercontinental Exchange I ICE Clear US 

55 East 52nd Street I 41st Floor I New York, NY 10055 

Tel: +1 212.748.4146 I Cell: L._ _________ J~l(~)_ __________ ___i 

hester.serafini@theice.com 

.. ':<~·:(< :;{:.·•<:;:.;· .. ··t }:~:· ;;> :;•;:~·t.:.:.:..'-~ 

you ~:H"i.:, n:_>i ~{n intt:'.rxkd r,~::_::ipii_:,nt ::>f thi;::; 

Urn_:,ncn/pt::.:d ,~:k:c:tt"onic n·t_j\ i:> i •>i Becun.:'. ~:;nd the 

ijter:·t:~tt:'. :::·K :u-:;::; of con;n-:unk::~1ti:.>n vvhi.:,rt:'. prh/i:::_::y 

: r:·). h:; ::~-~;b~~idi:~tder; 

· ... -.<~>:):" ,.:;:,. 

: .... ~ <.-_.,;_k J,~:d ·to p\>\i"ide B.a-fequ.at":_:i;::; f: Jn, -.,,.-;,·...:,::<:-.... ~ (.:,,\._.; ;- .•. ...:>"·< 

d,~::>i: .:_x; 

-v::< tA:!~--~-~~--~; ~;: ,./v :~_;t:: :~~-,:= i\:;-~:l ,.~,:=; d ~: -;, d= ~, \· : uH>~~- ::~ :'..; ~: c.~~ ~s~;c ,:=de~ t ~,:=~,-::- n·k:~1 r:r; (/ C'.)tnrr:~;nk~i:(~on 
Message 

From: Eamonn Hahessy [Eamonn.Hahessy@theice.com] 

Sent: 10/12/2018 12:05:10 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =a2d0b8b95a0b46029f13 ebead b 73f297-Bussey, Brian]; Za idi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi]; Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew] 

CC: Hester Serafini [Hester.Serafini@theice.com]; Audrey Hirschfeld [Audrey.Hirschfeld@theice.com]; Alex Albert 

[Alex.Albert@theice.com]; Mohr, Julie A. [/O=CFTC/OU=Chicago/cn=Recipients/cn=jmohr]; Donovan, Eileen A. 

[/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN] 

Subject: RE: DRAFT Bitcoin Submission 18-XXX.docx (002).doc 

Attachments: Draft ICUS Digital Currency Contract Rules Change Filing 2018 10 08 v7.docx; ICUS DC rules 95a.pdf 

Dear All, 

Attached is a draft ICE Clear US submission addressing the cleadng of physically settled BTC futures .. as well as assodated 

draft changes to the ICE Clear US Rules. As Trabue mentions, we are in the process of assembling answers to your 

September 18th questions. We will provide those to you later today. 

Regards, 

Eamonn 

Eamonn Hahessy 

General Counsel and CCO of ICE Clear US 

Intercontinental Exchange I ICE Clear US 

55 East 52nd Street I 41 st Floor I New York, NY 1 0055 

Tel: +1 212.748.3964 I Cell: -+i (b)(6) 1 

eamonn.hahessy@theice.com , 

From: Trabue Bland 

Sent: Friday, October 12, 2018 11:29 AM 

To: Thornton, Charlie (cthornton@CFTC.gov) <cthornton@CFTC.gov>; bbussey@cftc.gov; azaidi@cftc.gov; 

mkulkin@cftc.gov 

Cc: Eamonn Hahessy <Eamonn.Hahessy@theice.com>; Hester Serafini <Hester.Serafini@theice.com>; Audrey Hirschfeld 

<Audrey.Hirschfeld@theice.com>; Alex Albert <Alex.Albert@theice.com> 

Subject: DRAFT Bitcoin Submission 18-XXX.docx (002).doc 

Charlie, Brian, Amir and Matt: 

Attached is a revised draft DCM submission for the physically delivered BTC future. The changes are mainly 

technical with exception of the discussion of our trading and clearing firm feedback. You should be receiving draft rules 

from ICUS shortly and answers to your questions from a few weeks ago. 

Thank you again for your review. Please let me know if you have any questions. 

Trabue 

Trabue Bland 
President, !CE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street 40th Floor ' Telephone: +1 770.916.7832 (Atlanta) I +1 212.748.4005 (New York) 

Mobile: {_ _____________ (b)(6) -·-·-·-·-·-·___! 

trabue.b!and@theice.com 

intercontinentalexchange.com 
Message 

From: Alex Albert [Alex.Albert@theice.com] 

Sent: 9/5/2018 12:45:28 PM 

To: Trabue Bland [Trabue.Bland@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: Charlies Wild Board Sausage 

I don't see how you can buy them commercially. 

From: Trabue Bland <Tral:me.Bland!dtheice.com> 

Date: Wednesday, Sep 05, 2018, 12:23 PM 

To: Thornton, Charlie (cthomton@CFTC.gov) <cthornton(dCFTC.Qov>, Alex Albert <AJex AJben,iithcice.com> 

Subject: Charlies Wild Board Sausage 

https://yalealumnimagazine.com/articles/4565-charlie-munford 

Trabue Bland 

President, !CE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street, 40th Floor 

Telephone: +1 770.916.7832 (Atlanta) I +i 212.748.4005 (New York) 

Mobile: L _____________ (b)(GJ ______________ ___i 

trnbue.b!and@theice.com 

intercontinentalexchange.com 
Message 

From: Giancarlo, Chris [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=GIANCARLO, CHRIS2A4] 

Sent: 8/23/2018 4:25:03 PM 

To: Kelly.Loeffler@Bakkt.com 

CC: Kershaw, Shivon [/O=CFTC/OU=Washington, DC/cn=Recipients/cn=skershaw]; Gorfine, Daniel 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel]; Richardson, Erica 

Elliott [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =90deca0aceef 45b393696dcc2f94f83a-Ri cha rd son, Erica]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: CFTC FinTech Forward 2018 - Invitation to Participate 

August 23, 2018 

Dear Kelly, 

On behalf of the U.S. Commodity Futures Trading Commission (CFTC), we are pleased to invite you to participate as a 

panelist at our upcoming conference "FinTech Forward 2018: Innovation, Regulation and Education" scheduled for 

October 3-4, 2018 at the CFTC's Washington, D.C. Headquarters. This conference serves as the inaugural collaborative 

effort between LabCFTC, the agency's initiative focused on facilitating market-enhancing FinTech innovation, and the 

Office of Customer Education and Outreach, the agency's public education outreach division. The collaboration 

underscores the Agency's multi-pronged approach to keeping pace with a rapidly changing market and ensuring market 

integrity. 

The conference will convene innovators, regulators, and market participants, and interested members of the public to 

examine the wide range of Fin Tech issues impacting markets, including, but not limited to crypto assets, machine 

learning, cloud technologies, and RegTech. Conference participants will discuss the impact these technologies may have 

on markets and customers, and what regulators must do to remain forward-looking, mitigate risks, and educate 

customers and market participants on emerging challenges. The underlying spirit of the conference is in celebration of 

World Investor Week, a week-long, global campaign promoted by the International Organization of Securities 

Commissions (!OSCO), in which the CFTC serves as a member. 

Specifically, should you wish to participate in the conference, we are interested in having you speak on the "Crypto 

Assets Markets and Trading" panel which is scheduled from 9:30 a.m. - 10:30 a.m. on Wednesday, October 3, 2018. 

This panel will feature other leading experts and discussion will be led by a moderator. The purpose of the panel will 

focus on developments in crypto asset markets. It will explore market structure, cash trading, and developing derivatives 

markets. It will further discuss the risks associated with the marketplace for institutional investors and retail customers. 

Please note that panel format is a moderated discussion; no formal remarks or presentation are expected. The 

moderator will contact all panel participants prior to the conference to review the panel topic and answer any 

questions. 

Please note that if you elect to voluntarily participate in the conference as a panelist, you would be doing so on an 

uncompensated basis. Additionally, any costs associated with your participation in the conference, including travel and 
related expenses, would be your responsibility and the Commission would not be obligated to reimburse you for any 

such costs. 

Please RSVP no later than August 31, 2018 by emailing Shivon Kershaw at fintechforward@cftc.gov or by calling 202-

418-5017. Further logistical informational and details will be provided upon receipt of your RSVP. We hope you can join 

us. 

Sincerely, 

J. Christopher Giancarlo 

Chairman 

U.S. Commodity Futures Trading Commission 

cc: 

Daniel Gorfine 

Director, LabCFTC and Chief Innovation Officer 

Erica Richardson 

Director, Office of Public Affairs 
Message 

From: Sklar, Maggie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=SKLAR, 

MAGGIECA3] 

Sent: 7/23/2018 4:17:12 PM 

To: Trabue.Bland@theice.com 

CC: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Gorfine, Daniel 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel]; Zaidi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi] 

Subject: Block trades 

Hi Trabue, as I'd mentioned on the call this afternoon, the bitcoin submission on page 6 on block trades says it 

is allowed for "1- contracts" -- I'd interpreted that to mean 1 or more, particularly given the following 

commentary that allowing 1 block trades have previously been reviewed by the Commission. But confirming 

from our conversation, that that number should be "10." 

Also adding Amir since I don't know if he was aware of this discrepancy either. 

Thanks, 

Maggie 

Maggie Sklar 

Senior Counsel to Chairman J. Christopher Giancarlo 

U.S. Commodity Futures Trading Commission 

1155 21st Street, NW 

Washington, DC 20581 

(202) 418-5365 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 7/23/2018 11:56:42 AM 

To: Trabue Bland [Trabue.Bland@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; RJ Cummings 

[rj.cummings@theice.com]; Audrey Hirschfeld [Audrey.Hirschfeld@theice.com]; Alex Albert 

[Alex.Albert@theice.com]; Hester Serafini [Hester.Serafini@theice.com] 

Subject: Re: Dial in for today's call 

Thanks. 

On: 23 July 2018 11 :42, "Trabue Bland" <Trabue Bland(iDtheicecom> wrote: 

Charlie--lets use a dial in for the call--for those in NY, lets see if we can grab the Who conference room. 

Dial-in: 

8888 (or external number below) 

Meeting ID: 4005# 

Passcode:i

'·-·-·

(b)(4) j 

-·-·-·-·-·-·-·-·-·-· .. 

External numbers: 

Inside the US 

Atlanta 1-770-618-8888 

Chicago 1-312-596-4412 

Houston 1-713-815-7276 

New York 1-212-896-2810 

San Mateo 1-650-581-5603 

Trabue Bland 

President, !CE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street, 40th Floor 

Telephone: +1 770.916.7832 (Atlanta) I +1 212.748.4005 (New York) Mo bi I e: {·-·-·-·-·-·-·-·-(bW5)·-·-·-·-·-·-·-·-·: 

trnbue.b!and@theice.com 

intercontinentalexchange.com 

pl~:::~~~~e dehA~::: :t Hnd n::.tJy the ~~.enzk:t. i rm~. rn::.::~:~~aq::.: n t.:'J nr::~ :\:pt~:::H.:rt th.: r::pink::n of intet::.>:)n~:n::.:ntai i~~xch~~nsF:, =n::. .. 

net (;(;:)~~utute t: :-__:- )~ :~: ,:::~~~ .,__' :.:~ ' ' , .... , -~:, Un::.:n(:r:/pted ej~:::ct:\>ni::.:: ft:~~n i~~ net s~~:~~un~: -~L :',; d ~~::: : \_~:~,,;:_:,;~:::;·)( , ... )· :.;-);b :n.~:~.;.•v·d~ji.~: iS 
Message 

From: Jason Fusco [Jason.Fusco@theice.com] 

Sent: 7/20/2018 5:37:17 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Adm inistrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; 

FOIAsubm issions [/O=CFTC/OU=Washington, DC/cn=Recipients/cn=FOIAsubmissions] 

CC: Trabue Bland [Trabue.Bland@t heice.com] 

Subject: Request for Confidential Treatment 

Attachments : FOIA request-7.20.18.pdf 

Dear Mr. Thornton, 

Attached, please find a request for confidential treatment of the contract terms and conditions and all accompanying 

information provided to you by Mr. Trabue Bland on or about Friday, July 13, 2018. 

Feel free to contact me with any questions. 

Best regards, 

Jason 

Jason Fusco 

Assistant General Counsel - Market Regulation 

Intercontinental Exchange I ICE Futures U.S., Inc. 

55 East 52nd Street I New York, NY 10055 I 41 st Floor 

Tel: 212.748.4021 I Fax: 212.748.4089 

jason.fusco@theice.com 

www.theice.com 

~ ; ~~~-=- ;:1,.:;-:;~-~-=-,:~:}'-:'.- ; : ~,::i ~:~;-~ :·,.:'.-:-.): ~::~Y:'.°) ::· c:phk::n '.A jnt~~: ;~;~:-~;) :,-:'.-: ;;·d ;:~:x~ .. ;1d ):F-:'.-. ; 

JUt<:·~~~ ~e-~:. Unen(:ryptez:j ~::+:::ctrcnic n·i~~n i~~ net s~~:~~un~: ,~L =',; d ~~::: = \_~:~,.;:_:,;~:::;·)\ , • .-)· :.;-);-> :n.~:~.,•v·d~ji.~: iS 
ice 

July 20, 2018 

BY ELECTRONIC MAIL 

Assistant Secretary of the Commission for FOIA Matters, 

Privacy and Sunshine Acts Compliance 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

Re: FOIA CONFIDENTIAL TREATMENT REQUEST 

Dear Sir or Madam: 

In accordance with Commission Regulation 145.9(d), ICE Futures U.S., Inc. ("Exchange") 

requests confidential treatment pursuant to the Freedom oflnformation Act, 5 U.S.C. 552, for the 

contract specifications sent to Mr. Charles Thornton III, of the Office of Legislative Affairs, on 

July 13, 2018, and all accompanying materials. 

The Exchange is requesting confidential treatment for the aforementioned pursuant to 

Commission Regulation 145.9(d)(l)(i), (ii) and (vi), on the grounds that disclosure of the 

material: 

(d)(l)(i) is specifically exempted by a statute that either requires 

that the matters be withheld from the public in such a manner as 

to leave no discretion on the issue or establishes particular 

criteria for \vithholding or refers to particular types of matters to 

be withheld; or 

(d)(l)(ii) - would reveal confidential commercial or financial 

information. 

The Exchange further requests that the aforementioned receive confidential treatment in 

perpetuity. If you have any questions, please contact me at (212)748-4021 or 

jason.fusco!altheice.com. 

Very truly yours, 

Jason V. Fusco 

Assistant General Counsel 

ICE Futures U.S., Inc. 

cc: Charles Thornton III, Commodity Futures Trading Commission 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 7/16/2018 4:29:44 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Zaidi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi]; Donovan, Ei leen A. 

[/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN]; Bussey, Brian [/o=CFTC/ou=Exchange 

Administrative Group (FYDI BOH F23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian] 

Subject: DRAFT- Bitcoin Submission 18-XXX.docx.pdf 

Attachments: DRAFT- Bitcoin Submission 18-XXX.docx.pdf 

All: 

I 

L--·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·

(b)(4) i -·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·~ 

Trabue 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 7/12/2018 10:32:43 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: Virtual Currency Clearing Rules 

Great. Thanks! 

From: Thornton, Charlie <cthorntonra)CFTC.gov> 

Date: Thursday, Jul 12, 2018, 7:15 PM 

To: Trabue Bland <Trabue.Bland(al,theice,com>, Thornton, Charlie <cthornton(«ilCFTC.gov>, Zaidi, Amir 

<AZaidi@,CFTC.gov>, Bussey, Brian <BBusseyicz),CFTC.gov>, Donovan, Eileen A. <edonovan@,CFTC.gov> 

Cc: Audrey Hirschfeld <Audrey.Hirschfeld(a.)theice.com>, Hester Serafini <Hester.Serafinila),theice.com>, Alex Albert 

<Alex.Albert(wtheice.com> 

Subject: Re: Virtual Currency Clearing Rules 

WARNING - External email; exercise caution 

Thank you Trabue for this and the exchange draft. I will leave it to the experts here to review. 

Charlie 

On: 12 July 2018 18:07, "Trabue Bland" <Trabue.Bland@theice.com> wrote: 

Charlie, A.rnir, Brian, and Eileen: 

Attached are the clearinghouse rules as discussed in my previous email. Hester helpfully included a 

summary of the rules and a blackline against the current rules. 

Again, thank you very nmch for your tiine and effort. Please call us with any questions. 

Trabue 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 7/12/2018 5:59:53 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Zaidi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Donovan, Eileen A. 

[/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN] 

CC: Audrey Hirschfeld [Audrey.Hirschfeld@theice.com]; Hester Serafini [Hester.Serafini@theice.com]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: Virtual Currency Exchange Submission (Draft) 

Attachments: Bitcoin Submission 18-XXX.docx.pdf 

Charlie, Amir, Brian and Eileen: 

Attached please find a draft submission for the Bitcoin exchange rules. By separate email, I will send the 

clearinghouse rules. Please note that we are in active dialogue with clearing members, so please consider this a work in 

progress as we work with clearing and trading firms. We will update the filing with clearing member feedback as 

discussed in the May 21 Advisory. 

I would appreciate you keeping our draft submission confidential until we make our formal announcement (we 

are aiming to announce in the next two weeks). Any comments or questions would be appreciated. 

Thank you again for your review. 

Trabue 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 6/11/2018 9:48:27 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: RE: ICE drops grain futures contracts competing with CME 

PS--if you ever feel bad about the press--note they only time Greg Meyers writes about IFUS is when we deilst a 

contract! 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Monday, June 11, 2018 9:46 AM 

To: Trabue Bland <Trabue.Bland@theice.com>; Alex Albert <Alex.Albert@theice.com> 

Subject: RE: ICE drops grain futures contracts competing with CME 

WARNING - External email; exercise caution 

Ok. Sounds good. Thanks! 

From: Trabue Bland [mailto:Trabue,Bland@theice.com] 

Sent: Monday, June 11, 2018 9:39 AM 

To: Thornton, Charlie; Alex Albert 

Subject: RE: ICE drops grain futures contracts competing with CME 

On Fdday--there has been little to no trading since inception--alt:hough I still get asked by ag firms to list grain 

contracts!!! As I tell them, if they hate the CME then they have to support the other contracts! 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Monday, June 11, 2018 9:35 AM 

To: Trabue Bland <Trabue.Bland@theice.com>; Alex Albert <Alex.Albert@theice.com> 

Subject: FW: ICE drops grain futures contracts competing with CME 

WARNING - External email; exercise caution 

When did this happen? 

From: FIA SmartBrief [mailto:fia@smartbrief.com] 

Sent: Monday, June 11, 2018 8:43 AM 

To: Thornton, Charlie 

Subject: ICE drops grain futures contracts competing with CME 

June11,2018 
· 

· 

rt ri f I 

TOP STORIES 

CFTC seeks exchanges' data on bitcoin futures trading 

The Commodity Futures Trading Commission is asking cryptocurrency exchanges Coinbase, Bitstamp, itBit and Kn, 

futures pricing. The exchanges had denied CM E's request for the data through a third party, sources say, and the C 

manipulated. 

The Wall Street Journal (tiered subscription model) Financial Times (subscription required) 

mn~llltlE 

ICE drops grain futures contracts competing with CME 

Intercontinental Exchange has announced it will stop listing US corn, wheat, soybean, soybean oil and soybean me, 

Financial Times (subscription required) 

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German minister suggests Frankfurt handle euro clearing 

German Finance Minister Olaf Scholz wants euro clearing in London relocated to Frankfurt, Germany, after Brexit "i 

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Investment banks' profits surpass precrisis levels 

The world's nine largest investment banks recorded profits of $78.4 billion in 2017, up from $75.4 billion in 2007. Ho 

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Code of conduct would draw cryptocurrency investors, experts say 

Institutional investors might be more apt to invest in cryptocurrencies if a code similar to the FX Global Code of Con 

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• ICAP energy-business founder Newman to retire this month 

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Chinese financial-technology firms aim to expand into Southeast Asia as more financial institutions tap big data and 

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South China Morning Post (Hong Kong) 

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COMMODITIES AND MANAGED FUTURES 

Euronext eyes cash-settled grain futures contracts 

Euronext is considering adding cash-settled European durum-wheat and feed-barley futures contracts, though it hai 

what they want, what they need, and we are looking at how it can be done," says Nicholas Kennedy of Euronext. 

Hellenic Shipping News Worldwide/Bloomberg 
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Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 6/7/2018 9:45:13 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: Two articles on the secret SEC effort in crypto 

As you can see, someone at the SEC is giving someone positive signals here--Goldman (remember that Clayton used to 

represent Goldman) doesn't roll into this stuff randomly! 

https://1t,rw'w.wsi.corn/artides/rninbase-expands-with-deaHor-broker-dealer-keystone-capital-l52832.1.468 

Goldn1an-backed ccypto platforn1 Circle seeks banking license 

EJ Insight 

7 June 2018 

378 Yvords 

Engiisi, 

EJIM:H 

Copy!'!Qht 2044 Hong l<onQ Economic Journal AH R!Qhts Reserved 

• 

• 

Cryptocurrency and payments platform Circle Internet Financial plans to seek a federal banking license and also 

pursue registration as a brokerage and trading venue with the US Securities and Exchange Commission (SEC), 

Bloomberg reports. 

Circle, which counts Goldman Sachs among its backers, has had preliminary talks with the US Office of the 

Comptroller of the Currency about obtaining a federal banking license, according to the report 

Meanwhile, the fintech startup is also said to have some contact with staff at the SEC and officials from the Financial 

Industry Regulatory Authority (FINRA), which oversees brokerages. 

Circle, which is headquartered in Boston, is likely to pursue SEC regulation before the banking license, according to 

the report, which noted that registration with the SEC will allow the platform to sell tokens that are considered 

securities. 

CEO Jeremy Allaire was quoted as saying that with a bank charter, the firm can hold customer assets in the form of 

digital coins or government-issued currencies like US dollars, while opening doors to other components of the 
financial system, such as getting native access to the central banking system without intermediaries and directly 

settling with other banks in other markets worldwide. 

That will help "improve the efficiency of what we deliver" and can reduce the costs, he said. 

The report noted that while Circle would be subjected to tough scrutiny, getting a banking license will narrow the 

field of regulators the firm must appease, as federal laws would pre-empt a patchwork of state rules covering crypto. 

"You're able to have a single conversation. Ifs hard to have 50 conversations," Robert Bench, chief compliance 

officer of Circle told Bloomberg, referring to the move that would help cut down on the number of regulators the 

platform needed to work with. 

Coin base, another titan of US cryptocurrency trading, announced on Wednesday that it is acquiring a trio of firms 

including a broker-dealer registered with FINRA 

It will use licenses it obtains to offer customers blockchain-based securities if US regulators give the nod. The 

cryptocurrency trading platform has also broached the topic of a potential banking license with regulators, according 

to Bloomberg sources. 

- Contact us at english@hkej.com 

BN/RC 

Hong Kong Economic Journal Company Limited 

Document EJINST0020180607ee67000ul 

Trabue Bland 

President, ICE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street 40th Floor ' Telephor;i_~_: __ :1J._?ZQJ3_1_§J'.?_~2 (Atlanta) I +1 212.748.4005 (New York) 

Mobile: 1 (b)(G) i 

trabue.b!and@theice.cm11 

intercontinentalexchange.com 
Message 

From: Pham, Victor [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=85D1C61A99FD4390B7094831974D1777-PHAM, VICTOR] 

Sent: 6/6/2018 11:23:27 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: good overview of the topic 

,-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-

! Non-Responsive I L--·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·. 

From: Thornton, Charlie 

Sent: Wednesday, June 06, 2018 11: 16 AM 

To: Pham, Victor 

Subject: RE: good overview of the topic 

Non-Responsive 

From: Pham, Victor 

Sent: Wednesday, June 6, 2018 11:09 AM 

To: Thornton, Charlie 

Subject: RE: good overview of the topic 

Non-Responsive 

From: Thornton, Charlie 

Sent: Tuesday, June 05, 2018 1:12 PM 

To: Pham, Victor 

Subject: RE: good overview of the topic 

l __Non-_Respo_nsive __ ! 

From: Thornton, Charlie 

Sent: Tuesday, June 5, 2018 11:26 AM 

To: Pham, Victor 

Subject: FW: good overview of the topic 

From: Trabue Bland [mailto:TrabueJ31and@theice,com] 

Sent: Monday, June 4, 2018 3:15 PM 

To: Thornton, Charlie; Alex Albert 

Subject: FW: good overview of the topic 

Charlie--
This is the point I was trying to make about the importance of custodians/warehouses--this is a good overview 

of the issues in the current custody space. 

Custody: Unchartered Waters for Digital 

Assets 

CHRIS KEl'JTOURIS LEAVE A COMMENT 

Qualified custodian. That's a term that compliance and operations managers at registered investment fund advisors, 

not to mention the US Securities and Exchange Commission, are now grappling with, when it comes to the 

safekeeping of digital assets. 

The reason is two-fold. For starters, it is unclear whether the SE C's custody rule for RIAs investing in traditional 

assets applies to cryptocurrencies such as Bitcoin and Ether. Then, even if it does apply, the available service 

providers aren't exactly household names. They are relative newcomers to the field, and not all fall under the SEC's 

categories for a qualified custodian. 

The requirement for registered investment advisors to hire a "qualified custodian" for securities or funds dates back 

to the pre-digital era before virtual assets such as Bitcoin and other cryptocurrencies existed. The SEC's "custody 

rule" for registered investment advisors, outlined in the Investment Advisers Act of 1940, defines a qualified 

custodian as a bank, broker-dealer, trust company, futures commission merchant, or foreign financial institution. So 

far, the regulatory agency hasn't classified Bitcoin, Ether or any other cryptocurrency as a security or a fund. 

Therefore, one could argue that RIAs don't have to select a qualified custodian . 

Legal Quagmire 

Would the SEC penalize an RIA for doing its own custody work or for selecting a firm that doesn't meet the SEC's 

definition of qualified custodian? Legal and compliance experts specializing in cryptocurrencies aren't certain. There 

are plenty of crypto-funds - those dedicated to investing in cryptocurrencies and initial coin offerings - doing their 

own custody. However, they aren't RIAs. 

"The SEC's custody rule doesn't require the use of independent custodians, but there are additional requirements 

the RIA must adhere to when it or an affiliate hold digital assets," explains Jesse Brown, a compliance associate 

with financial services consultancy Cordi um in New York. Those extra steps include receiving internal control reports 

and surprise exams from an accountant certified by the Public Company Accounting Oversight Board. 

Some attorneys tell FlnOps that they would urge their RIA clients investing in digital assets to pick a qualified 

custodian to avoid the SEC setting policy after it has actually fined a firm. Even if the agency hadn't already provided 

specific guidance for this situation, it could always justify its penalty under the guise of investor protection. The SEC 

hs frequently done so. 

RIAs who ultimately decide to safekeep their own digital assets need to be extra careful. "They should consult with 

the SEC first,'' cautions Verity Van Tassel Richards, an attorney with McDermott, Will Emery in New York, who 

spoke at a recent event hosted by the Accounting Blockchain Coalition. "The SEC hasn't issued definitive guidance 

about custody of digital assets and seems open to talking about this issue." 

Yet the SEC wouldn't respond to questions posed by FinOps Report about how it interprets its 1940 custody rule in 

terms of digital assets. Instead it referred the publication to a letter sent to the Securities Industry and Financial 

Services Authority and the Investment Company Institute earlier this year, which suggests that the SEC is still 

formulating its policy. "To the extent a fund plans to hold cryptocurrency directly, how would it satisfy the custody 
requirement of the 1940 Act and relevant rules?" questions Dalia Blass, the director of the SEC's investment 

management division, the author of the letter. 

The SEC is apparently so concerned about the self- custody of digital assets that it is examining crypto-funds, say 

media outlets. There are an estimated 220 crypto-focused hedge funds that manage at least US$3.5 billion in 

assets, according to Autonomous Research, a research firm which analyzes financial firms. Because many of the 

funds oversee less than US$150 million in assets, they aren't required to register with the SEC and at best are only 

regulated by the state in which they are based. 

Tough Choices 

RIAs won't have an easy time selecting a custodian for digital assets. Among the well-known custodians for 

traditional assets, only State Street Bank has publicly announced that it is exploring the possibility of offering 

custody for digital assets to institutional investors. 

In its January 2018 letter to SIFMA and the ICI, the SEC's Blass says the agency doesn't know of any custodians 

providing fund custodial services for cryptocurrencies. Yet some firms claim they fall into one of the SEC's 

categories for a qualified custodian. 

The Murray, Kentucky-based Kingdom Trust says it meets the SEC's definition because it is registered as a trust 

company in South Dakota. The firm, which started off in 2009 as a custodian of alternative assets for retirement 

accounts, began to offer custody of digital assets in late 2016 through Silicon Valley tech upstart BitGo, which 

serves as its technology provider. In January 2018 BitGo announced it would take over Kingdom Trust but recently 

said it would scrap the deal in favor of building its own custody business as a trust company. BitGo, which already 

provides custodian services for Kracken, CME Group, Pantera Capital, The Royal Mint and UPbit, also just added 

crypto-backed loans provider Nexo to its client list. 

Yet Kingdom Trust's Chief Executive Officer Matt Jennings is quick to downplay the competitive threat. "Kingdom 

Trust was the leader in the digital asset custodial space long before contemplating this merger with BitGo," he tells 

FinOps Report. "Kingdom Trust will continue to lead this space as the permier provider of custodial services and 

plans to release several new products very soon that will greatly expand the options for institutional investors 

seeking qualified custody and security of digital assets." 

There are other potential contenders for the business. Cryptocurrency exchanges Genesis and itBit are registered 

as trust companies in New York. Coin Base, the largest US cryptocurrency exchange, says it will also offer custody 

services. Now registered as a money transmitter, Coin Base has publicly said it wants to become an alternative 

trading platform and broker-dealer. Another possible candidate, the Secaucus, New Jersey-based newcomer Digital 

Asset Custody did not respond to emails seeking comment 

Xapo, a Palo-Alto, California based money transmitter, which provides custodial services for Bitcoin only, says that it 

has won plenty of business from institutional investors even though it technically isn't a "qualified" custodian. The 

four-year old firm, founded by Argentine entrepreneur Wences Casares, has been marketing to pension plans, 

private funds, family offices and hedge funds. So far, it has amassed an estimated US$10 billion in Bitcoins under 

custody, according to media reports. Xapo, whose billionaire clients include Linkedin co-founder Reid Hoffman and 

former Wall Street trader Mike Novogratz, won't confirm that figure. 

"Bitcoin has not been classified by the SEC and frankly it's hard to imagine that it would fit the definition of a 

security," says Ted Rogers, Xapo's president who was a panel ist at the event hosted by the Accounting Blockchain 

Coalition in New York. "The SEC's public comments so far seem to support the position that it isn't. '' 

Rogers wouldn't disclose the number of RIA's using Xapo to safekeep their Bitcoin assets, but he acknowledges 

that many RIAs are concerned about falling afoul of the SEC's narrow categories of qualified custodians. Meeting 

the definition, does give Kingdom Trust, Genesis and others a competitive edge. 
Incorporated in Delaware as a money transmitter, Xapo's US subsidiary is regulated by the US Treasury's Financial 

Crimes Enforcement Network. So far, Xapo has been examined once by the Internal Revenue Service, FinCEN's 

enforcement arm, and Rogers expects exams to occur at least every two years. Xapo's Swiss subsidiary is 

overseen by the Swiss self-regulatory regulatory agency, the Financial Services Standards Authority. To level the 

playing field with US rivals by meeting the SEC's definition of a qualified custodian, Xapo will be teaming up with a 

custodian bank to serve as the primary custodian with Xapo as the subcustodian. 

Kingdom Trust might fall under the technical definition of a qualified custodian, but its rivals won't hesitate to point 

out that South Dakota isn't the toughest regulatory state. Kingdom Trust's Jennings insists that isn't so. The South 

Dakota Division of Banking subjects his firm to an exam every 12 to 18 months, he says. 

How much clout that gives Kingdom Trust among RIAs, when it comes to safekeeping digital assets, can't be 

determined. Jennings would not disclose the number of RIAs using Kingdom Trust to safeguard their digital assets, 

nor would he estimate what percentage of the US$12 billion in assets under custody reflects digital assets. 

Chad Cascarilla, chief executive of the New York-based itBit, also would not disclose the value of digital assets his 

firm has under custody. However, he points to the fact that more than ten "well-known" registered investment 

advisors use itBit to safeguard their Bitcoin holdings as evidence that accreditation does matter. So does the legal 

entity offering it. "The status of a trust that is organized under New York banking law and the oversight of the New 

York Department of Financial Servics is the most rigorous among states," says Cascarilla. ltBlt is subject to an 

annual regulatory exam of its policies and procedures. That onsite review, which includes testing of its security 

protocols, can last up to five weeks. 

Operational Due Diligence 

Digital currency experts say that the legal designation of the digital asset custodian should be only one of the criteria 

an RIA should use in the selection process. "What are the backgrounds of the directors of the firm, how will the firm 

segregate client assets so that clients can have ready access in the event of the service provider's bankruptcy, and 

how will they protect assets from hacking are basic questions are the basic questions RIAs should ask," says Will 

Coleman, director of technology advisory services at Cohen & Co, a Cleveland, Ohio-based accounting firm 

specializing in audits and tax issues for crypto-funds. 

Van Tassel Richards also recommends that fund managers ask how long the service provider has been offering 

custody of digital assets, whether it has experienced any security breaches, whether it follows know-your-customer 

and anti-money laundering rules and whether it has received any legal opinion or SEC guidance. That legal opinion 

or guidance would indicate whether the service provider's systems, policies and procedures meet the requirements 

of the agency's custody rule. 

Breadth of digital assets covered and security provisions will likely also differentiate service providers, says Rogers. 

Kingdom Trust provides custody services for Bitcoin, Ether and other cryptocurrencies, while Xapo says it has no 

intention of expanding beyond Bitcoin. itBit says it plans to expand its reach beyond Bitcoin to other 

cryptocurrencies. 

Costly Security 

All of the digital asset custodians use similar phrasing when discussing their ultra-tight security measures, which aim 

to safeguard private keys - or access to client assets. Those extra precautions come at a steep cost for clients. 

Whereas traditional custodians might charge only one or two basis points for safekeeping services, digital 

custodians could charge anywhere from 50 to 100 basis points, RIAs tell FinOps. 

Xapo, Kingdom Trust and itBit would not discuss their fees. All say that to mitigate the potential for hacking, they 

hold the private keys - or signatures for access - to the digital assets they safekeep offline or outside of any 

network. Xapo, Kingdom Trust, and itBit would not disclose how many employees hold those keys or who they are. 
"We store the private keys to the assets at multiple vaults, in multiple undisclosed locations and our security 

protocols require multiple signers from multiple locations and multiple institutions to sign off on transactions," 

explains Kingdom Trust's Jennings, a former real-estate investor. It could take up to 24 bours to withdraw or deposit 

any digital assets with Kingdom Trust. 

Rogers says that Xapo keeps the private keys to over 95 percent of the Bitcoins under custody at multiple 

underground vaults across the globe, including one in a decommissioned Swiss military bunker. Signatures by 

multiple private keys are required for any transactions to occur - a process which could take up to two days to 

complete. To ensure clients can access some their assets more quickly, Xapo also stores private keys to a small 

amount of Bitcoins online with Xapo employees overseeing those transactions. 

The extraordinary security steps reduce the potential for digital assets to be stolen by either an insider or hacker to 

close to nil, say digital asset custodians. However, it can happen, as evidenced by the breach in 2016 of 

cryptocurrency exchange Bitfinex. Bitfinex, used BitGo's software as its security platform, but BitGo denied 

responsibility for the hacking, which resulted in Bitfinex's losing about US$70 million of Bitcoins. 

RIAs can't count on the comfort of their digital asset custodian's insurance policy. Jennings says that Kingdom Trust 

is working with a large unnamed insurance provider to provide such a policy, but would not discuss what the policy 

would cover. Carascilla says that itBit will offer insurance to customers upon request. However, that insurance would 

only compensate a customer due to the loss of an asset from a catastrophic natural disaster, not a hackeL 

Xapo's Rogers says that his firm no longer buys insurance to compensate clients for potential asset loss because of 

"irrational" risk premiums. Instead, Xapo relies on a separate reserve fund of its own Bitcoins to cover client assets. 

"It is difficult for insurance firms to effectively calculate the risk of loss beause the Bitcoin industry is so new," notes 

Rogers. So far, Xapo has not used its reserve fund to compensate any clients. 

Just as important as not losing one's assets is having access to one's assets. Rogers acknowledges that there have 

been cases where Xapo held up a fund manager's transfer of Bitcoin to its own private wallet. However, he insists 

that the need to follow rigorous security procedures and verify the identity of th fund manager, not technology flaws, 

were the cause of the delay. The fund manager did eventually receive the assets within an undisclosed time. 

Given that digital asset custodians use different terminology than traditional custodians in describing their assetprotection services, registered investment advisors might have a hard time understanding just what they are buying. 

Coleman recommends that compliance managers at RIAs ask legal and auditing firms specializing in cryptocurrency 

and blockchain for referrals on service providers they have worked with. 

Another safeguard: asking the custodian whether it has received any third-party certification of its policies and 

procedures for financial reporting and systems. Such certifications known as "SOCs", short for service organization 

controls, come in three categories. Xapo has won a SOC I and SOC II Type 1 certifications while itBit is working on 

a SOC I certification and Kingdom Trust is working on a SOC II certification. The SOC I certification covers financial 

reporting while SOC II also incorporates rigorous operating procedures for security, processing integrity and data 

privacy. 

All of the extra diligence RIAs perform to pick the right digital asset custodian might not be enough to ward off a 

potential conflict with the SEC. "RIAs who select a qualified custodian's can't always depend on the custodian to 

safekeep all of the digital assets," cautions Daniel Viola, a parter in charge of the crypto and regulatory practices at 

the law firm of Sadis & Goldberg in New York. The reason: the custodian may only be willing to safekeep some of 

the types of digital assets the RIA is holding. 

What then? The RIA may be back to the self-custody option for the rest of its crypto-assets. That leaves the RIA 

subject to even further regulatory scrutiny on its policies and procedures. Transferring the assets to a remote coldstorage wallet is what Rogers recommends. 
rn~~v contain ~~z>r~fak)nUt:) jnfon~·~~=::l:bn ~~nd :ntenz:j::_:d ;ut ~~•t-"-~ .. j;;~,• ,·.·v•,,-,,.,,,.,,." ~-inie~~s expjk~iUy noted c:U·~(~:t\·',/i~~e. :1 ·y~;u j·~t:\/e reason to b)lk:v\) ":/OU~~:\~ 

=-~)p:\:s~)n~ th~) ::.+,= :-:)n o! jr-:te=-~~crhn~)nttd Exz)kW\F\ 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 6/5/2018 4:52:13 PM 

To: Trabue Bland [Trabue.Bland@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: Re: Testimony of Chairman J. Christopher Giancarlo before t he Senate Committee On Appropriations Subcommittee 

on Financial Services and General Government, Wash ington, D.C. 

Thanks. He did well at the hearing too! 

Charlie Thornton 

Director, Office of Legislative Affairs 

Commodity Futures Trading Commission 

202-418-5145 

On: 05 June 2018 16:50, "Trabue Bland" <Trabue.Bland@theice.com> wrote: 

This was a well done speech! 

From: CFTC.gov [mailto:cftc@service.govdelivery.com] 

Sent: Tuesday, June 05, 2018 4:36 PM 

To: Trabue Bland <Trabue.Bland@theice.com> 

Subject: Testimony of Chairman J. Christopher Giancarlo before the Senate Committee On Appropriations 

Subcommittee on Financial Services and General Government, Washington, D.C. 

WARNING - External email; exercise caution 

You are subscribed to Speeches and Testimony for CFTC.gov. This information has recently been updated, and 

is now available. 

Testimony of Chairman J. Christopher Giancarlo before the Senate Committee On 

Appropriations Subcommittee on Financial Services and General Government, 

Washington, D.C. 

Introduction 

Thank you, Chairman Lankford, Ranking Member Coons, and Members of the subcommittee. I appreciate the 

opportunity to appear before you today, along with my fellow colleague from the Securities and Exchange 

Commission (SEC), Chairman Jay Clayton ... 
Released: 06/05/2018 

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This 01,wil was Nml lo trabue. bland @theice.com 

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Message 

From: Pham, Victor [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=85D1C61A99FD4390B7094831974D1777-PHAM, VICTOR] 

Sent: 6/5/2018 1:13:10 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Adm inistrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: good overview of the topic 

[ ____ Non_-Resp_onsive ___ l 

From: Thornton, Charlie 

Sent: Tuesday, June 05, 2018 1:12 PM 

To: Pham, Victor 

Subject: RE: good overview of the topic 

i Non-Responsive i i·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·i 

From: Thornton, Charlie 

Sent: Tuesday, June 5, 2018 11:26 AM 

To: Pham, Victor 

Subject: FW: good overview of the topic 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Monday, June 4, 2018 3:15 PM 

To: Thornton, Charlie; Alex Albert 

Subject: FW: good overview of the topic 

Charlie--

This is the point I was trying to make about the importance of custodians/warehouses--this is a good overview 

of the issues in the current custody space. 

Custody: Unchartered Waters for Digital 

Assets 

CHRIS KENTOURIS LEAVE A COMMENT 

Qualified custodian. That's a term that compliance and operations managers at registered investment fund advisors, 

not to mention the US Securities and Exchange Commission, are now grappling with, when it comes to the 

safekeeping of digital assets. 

The reason is two-fold. For starters, it is unclear whether the SE C's custody rule for RIAs investing in traditional 

assets applies to cryptocurrencies such as Bitcoin and Ether. Then, even if it does apply, the available service 

providers aren't exactly household names. They are relative newcomers to the field, and not all fall under the SEC's 

categories for a qualified custodian. 

The requirement for registered investment advisors to hire a "qualified custodian" for securities or funds dates back 

to the pre-digital era before virtual assets such as Bitcoin and other cryptocurrencies existed. The SEC's "custody 

rule" for registered investment advisors, outlined in the Investment Advisers Act of 1940, defines a qualified 

custodian as a bank, broker-dealer, trust company, futures commission merchant, or foreign financial institution. So 
far, the regulatory agency hasn't classified Bitcoin, Ether or any other cryptocurrency as a security or a fund. 

Therefore, one could argue that RIAs don't have to select a qualified custodian. 

Legal Quagmire 

Would the SEC penalize an RIA for doing its own custody work or for selecting a firm that doesn't meet the SEC's 

definition of qualified custodian? Legal and compliance experts specializing in cryptocurrencies aren't certain. There 

are plenty of crypto-funds - those dedicated to investing in cryptocurrencies and initial coin offerings - doing their 

own custody. However, they aren't RIAs. 

"The SEC's custody rule doesn't require the use of independent custodians, but there are additional requirements 

the RIA must adhere to when it or an affiliate hold digital assets," explains Jesse Brown, a compliance associate 

with financial services consultancy Cordi um in New York. Those extra steps include receiving internal control reports 

and surprise exams from an accountant certified by the Public Company Accounting Oversight Board. 

Some attorneys tell FlnOps that they would urge their RIA clients investing in digital assets to pick a qualified 

custodian to avoid the SEC setting policy after it has actually fined a firm. Even if the agency hadn't already provided 

specific guidance for this situation, it could always justify its penalty under the guise of investor protection. The SEC 

hs frequently done so. 

RIAs who ultimately decide to safekeep their own digital assets need to be extra carefuL "They should consult with 

the SEC first," cautions Verity Van Tassel Richards, an attorney with McDermott, Will Emery in New York, who 

spoke at a recent event hosted by the Accounting Blockchain Coalition. "The SEC hasn't issued definitive guidance 

about custody of digital assets and seems open to talking about this issue." 

Yet the SEC wouldn't respond to questions posed by FinOps Report about how it interprets its 1940 custody rule in 

terms of digital assets. Instead it referred the publication to a letter sent to the Securities Industry and Financial 

Services Authority and the Investment Company Institute earlier this year, which suggests that the SEC is still 

formulating its policy. "To the extent a fund plans to hold cryptocurrency directly, how would it satisfy the custody 

requirement of the 1940 Act and relevant rules?" questions Dalia Blass, the director of the SEC's investment 

management division, the author of the letter. 

The SEC is apparently so concerned about the self- custody of digital assets that it is examining crypto-funds, say 

media outlets. There are an estimated 220 crypto-focused hedge funds that manage at least US$3.5 billion in 

assets, according to Autonomous Research, a research firm which analyzes financial firms. Because many of the 

funds oversee less than US$150 million in assets, they aren't required to register with the SEC and at best are only 

regulated by the state in which they are based. 

Tough Choices 

RIAs won't have an easy time selecting a custodian for digital assets. Among the well-known custodians for 

traditional assets, only State Street Bank has publicly announced that it is exploring the possibility of offering 

custody for digital assets to institutional investors. 

In its January 2018 letter to SIFMA and the ICI, the SEC's Blass says the agency doesn't know of any custodians 

providing fund custodial services for cryptocurrencies. Yet some firms claim they fall into one of the SEC's 

categories for a qualified custodian. 

The Murray, Kentucky-based Kingdom Trust says it meets the SEC's definition because it is registered as a trust 

company in South Dakota. The firm, which started off in 2009 as a custodian of alternative assets for retirement 

accounts, began to offer custody of digital assets in late 2016 through Silicon Valley tech upstart BitGo, which 

serves as its technology provider. In January 2018 BitGo announced it would take over Kingdom Trust but recently 
said it would scrap the deal in favor of building its own custody business as a trust company. BitGo, which already 

provides custodian services for Kracken, CME Group, Pantera Capital, The Royal Mint and UPbit, also just added 

crypto-backed loans provider Nexo to its client list 

Yet Kingdom Trust's Chief Executive Officer Matt Jennings is quick to downplay the competitive threat "Kingdom 

Trust was the leader in the digital asset custodial space long before contemplating this merger with BitGo," he tells 

FinOps Report "Kingdom Trust will continue to lead this space as the permier provider of custodial services and 

plans to release several new products very soon that will greatly expand the options for institutional investors 

seeking qualified custody and security of digital assets." 

There are other potential contenders for the business. Cryptocurrency exchanges Genesis and itBit are registered 

as trust companies in New York. Coin Base, the largest US cryptocurrency exchange, says it will also offer custody 

services. Now registered as a money transmitter, Coin Base has publicly said it wants to become an alternative 

trading platform and broker-dealer. Another possible candidate, the Secaucus, New Jersey-based newcomer Digital 

Asset Custody did not respond to emails seeking comment. 

Xapo, a Palo-Alto, California based money transmitter, which provides custodial services for Bitcoin only, says that it 

has won plenty of business from institutional investors even though it technically isn't a "qualified" custodian. The 

four-year old firm, founded by Argentine entrepreneur Wences Casares, has been marketing to pension plans, 

private funds, family offices and hedge funds. So far, it has amassed an estimated US$10 billion in Bitcoins under 

custody, according to media reports. Xapo, whose billionaire clients include Linkedin co-founder Reid Hoffman and 

former Wall Street trader Mike Novogratz, won't confirm that figure. 

"Bitcoin has not been classified by the SEC and frankly it's hard to imagine that it would fit the definition of a 

security," says Ted Rogers, Xapo's president who was a panelist at the event hosted by the Accounting Blockchain 

Coalition in New York. "The SEC's public comments so far seem to support the position that it isn't." 

Rogers wouldn't disclose the number of RIA's using Xapo to safekeep their Bitcoin assets, but he acknowledges 

that many RIAs are concerned about falling afoul of the SEC's narrow categories of qualified custodians. Meeting 

the definition, does give Kingdom Trust, Genesis and others a competitive edge. 

Incorporated in Delaware as a money transmitter, Xapo's US subsidiary is regulated by the US Treasury's Financial 

Crimes Enforcement Network. So far, Xapo has been examined once by the Internal Revenue Service, FinCEN's 

enforcement arm, and Rogers expects exams to occur at least every two years. Xapo's Swiss subsidiary is 

overseen by the Swiss self-regulatory regulatory agency, the Financial Services Standards Authority. To level the 

playing field with US rivals by meeting the SEC's definition of a qualified custodian, Xapo will be teaming up with a 

custodian bank to serve as the primary custodian with Xapo as the subcustodian. 

Kingdom Trust might fall under the technical definition of a qualified custodian, but its rivals won't hesitate to point 

out that South Dakota isn't the toughest regulatory state. Kingdom Trust's Jennings insists that isn't so. The South 

Dakota Division of Banking subjects his firm to an exam every 12 to 18 months, he says. 

How much clout that gives Kingdom Trust among RIAs, when it comes to safekeeping digital assets, can't be 

determined. Jennings would not disclose the number of RIAs using Kingdom Trust to safeguard their digital assets, 

nor would he estimate what percentage of the US$12 billion in assets under custody reflects digital assets. 

Chad Cascarilla, chief executive of the New York-based itBit, also would not disclose the value of digital assets his 

firm has under custody. However, he points to the fact that more than ten "well-known" registered investment 

advisors use itBit to safeguard their Bitcoin holdings as evidence that accreditation does matter. So does the legal 

entity offering it. "The status of a trust that is organized under New York banking law and the oversight of the New 

York Department of Financial Servics is the most rigorous among states," says Cascarilla. ltBlt is subject to an 

annual regulatory exam of its policies and procedures. That onsite review, which includes testing of its security 

protocols, can last up to five weeks. 
Operational Due Diligence 

Digital currency experts say that the legal designation of the digital asset custodian should be only one of the criteria 

an RIA should use in the selection process. "What are the backgrounds of the directors of the firm, how will the firm 

segregate client assets so that clients can have ready access in the event of the service provider's bankruptcy, and 

how will they protect assets from hacking are basic questions are the basic questions RIAs should ask," says Will 

Coleman, director of technology advisory services at Cohen & Co, a Cleveland, Ohio-based accounting firm 

specializing in audits and tax issues for crypto-funds. 

Van Tassel Richards also recommends that fund managers ask how long the service provider has been offering 

custody of digital assets, whether it has experienced any security breaches, whether it follows know-your-customer 

and anti-money laundering rules and whether it has received any legal opinion or SEC guidance. That legal opinion 

or guidance would indicate whether the service provider's systems, policies and procedures meet the requirements 

of the agency's custody rule. 

Breadth of digital assets covered and security provisions will likely also differentiate service providers, says Rogers. 

Kingdom Trust provides custody services for Bitcoin, Ether and other cryptocurrencies, while Xapo says it has no 

intention of expanding beyond Bitcoin. itBit says it plans to expand its reach beyond Bitcoin to other 

cryptocurrencies. 

Costly Security 

All of the digital asset custodians use similar phrasing when discussing their ultra-tight security measures, which aim 

to safeguard private keys - or access to client assets. Those extra precautions come at a steep cost for clients. 

Whereas traditional custodians might charge only one or two basis points for safekeeping services, digital 

custodians could charge anywhere from 50 to 100 basis points, RIAs tell FinOps. 

Xapo, Kingdom Trust and itBit would not discuss their fees. All say that to mitigate the potential for hacking, they 

hold the private keys - or signatures for access - to the digital assets they safekeep offline or outside of any 

network. Xapo, Kingdom Trust, and itBit would not disclose how many employees hold those keys or who they are. 

"We store the private keys to the assets at multiple vaults, in multiple undisclosed locations and our security 

protocols require multiple signers from multiple locations and multiple institutions to sign off on transactions," 

explains Kingdom Trust's Jennings, a former real-estate investor. It could take up to 24 bours to withdraw or deposit 

any digital assets with Kingdom Trust. 

Rogers says that Xapo keeps the private keys to over 95 percent of the Bitcoins under custody at multiple 

underground vaults across the globe, including one in a decommissioned Swiss military bunker. Signatures by 

multiple private keys are required for any transactions to occur - a process which could take up to two days to 

complete. To ensure clients can access some their assets more quickly, Xapo also stores private keys to a small 

amount of Bitcoins online with Xapo employees overseeing those transactions. 

The extraordinary security steps reduce the potential for digital assets to be stolen by either an insider or hacker to 

close to nil, say digital asset custodians. However, it can happen, as evidenced by the breach in 2016 of 

cryptocurrency exchange Bitfinex. Bitfinex, used BitGo's software as its security platform, but BitGo denied 

responsibility for the hacking, which resulted in Bitfinex's losing about US$70 million of Bitcoins. 

RIAs can't count on the comfort of their digital asset custodian's insurance policy. Jennings says that Kingdom Trust 

is working with a large unnamed insurance provider to provide such a policy, but would not discuss what the policy 

would cover. Carascilla says that itBit will offer insurance to customers upon request However, that insurance would 

only compensate a customer due to the loss of an asset from a catastrophic natural disaster, not a hacker. 
Xapo's Rogers says that his firm no longer buys insurance to compensate clients for potential asset loss because of 

"irrational" risk premiums. Instead, Xapo relies on a separate reserve fund of its own Bitcoins to cover client assets. 

"It is difficult for insurance firms to effectively calculate the risk of loss beause the Bitcoin industry is so new," notes 

Rogers. So far, Xapo has not used its reserve fund to compensate any clients. 

Just as important as not losing one's assets is having access to one's assets. Rogers acknowledges that there have 

been cases where Xapo held up a fund manager's transfer of Bitcoin to its own private wallet However, he insists 

that the need to follow rigorous security procedures and verify the identity of th fund manager, not technology flaws, 

were the cause of the delay. The fund manager did eventually receive the assets within an undisclosed time. 

Given that digital asset custodians use different terminology than traditional custodians in describing their assetprotection services, registered investment advisors might have a hard time understanding just what they are buying. 

Coleman recommends that compliance managers at RIAs ask legal and auditing firms specializing in cryptocurrency 

and blockchain for referrals on service providers they have worked with. 

Another safeguard: asking the custodian whether it has received any third-party certification of its policies and 

procedures for financial reporting and systems. Such certifications known as "SOCs", short for service organization 

controls, come in three categories. Xapo has won a SOC I and SOC II Type 1 certifications while itBit is working on 

a SOC I certification and Kingdom Trust is working on a SOC II certification. The SOC I certification covers financial 

reporting while SOC II also incorporates rigorous operating procedures for security, processing integrity and data 

privacy. 

All of the extra diligence RIAs perform to pick the right digital asset custodian might not be enough to ward off a 

potential conflict with the SEC. "RIAs who select a qualified custodian's can't always depend on the custodian to 

safekeep all of the digital assets,'' cautions Daniel Viola, a parter in charge of the crypto and regulatory practices at 

the law firm of Sadis & Goldberg in New York. The reason: the custodian may only be willing to safekeep some of 

the types of digital assets the RIA is holding. 

What then? The RIA may be back to the self-custody option for the rest of its crypto-assets. That leaves the RIA 

subject to even further regulatory scrutiny on its policies and procedures. Transferring the assets to a remote coldstorage wallet is what Rogers recommends. 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 5/30/2018 4:48:28 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: FYI 

Attachments: CryptoTradingAndPaymentEcosystem (004).pdf 

Overview 

~ r:·). h:; ::~-~;b~~jdj:~lde~:; t ~ut s.,,->: k<~-~.:-~e ,:~ d:· ~1~b;d: ~:·c :'. Ur:f;:n:::~·typt~::d e~ec-t:\;r+: ff:i:dj l~:; not r;:}{;Ut\~ t:r:d n~:i;: r:i;:{;ip :nt of "tj 

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Message 

From: Zaidi, Amir [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AZAIDI] 

Sent: 5/21/2018 3:26:34 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Donovan, Eileen 

A. [/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN]; Bussey, Brian [/o=CFTC/ou=Exchange 

Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; 

Kuserk, Gregory [/o=CFTC/ou=Washington, DC/cn=Recipients/cn=gkuserk]; Leahy, Thomas M., Jr. 

[/o=CFTC/ou=Washington, DC/cn=Recipients/cn=tleahy ]; Van Wagner, David [/o=CFTC/ou=Washington, 

DC/cn=Recipients/cn=dvanwagner]; Gorfine, Daniel [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel]; Raimondi, Philip 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOH F23SPDLT)/cn=Recipients/cn=Raimondi, Philip490] 

CC: Sklar, Maggie [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Sklar, 

Maggieca3]; Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =3a b6b606c58b45fe8b917 4d248b3fa65-G ii I, Mi cha el] 

Subject: RE: Warehouse legal overview 

! 

i-·-·-·-·-·-·-·-·-·-·

Non-Responsive ! -·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-i 

From: Thornton, Charlie 

Sent: Monday, May 21, 2018 3:22 PM 

To: Zaidi, Amir; Donovan, Eileen A.; Bussey, Brian; Kuserk, Gregory; Leahy, Thomas M., Jr.; Van Wagner, David; Gorfine, 

Daniel; Raimondi, Philip 

Cc: Sklar, Maggie; Gill, Michael 

Subject: RE: Warehouse legal overview 

Non-Responsive 

From: Zaidi, Amir 

Sent: Tuesday, May 15, 2018 3:47 PM 

To: Donovan, Eileen A.; Bussey, Brian; Kuserk, Gregory; Leahy, Thomas M., Jr.; Van Wagner, David 

Cc: Thornton, Charlie 

Subject: FW: Warehouse legal overview 

Non-Responsive 
Amir 

From: Trabue Bland [mailto:Trabue,Blandi1)theiG::,com] 

Sent: Tuesday, May 15, 2018 10:20 AM 

To: Zaidi, Amir; Thornton, Charlie 

Subject: Warehouse legal overview 

Amir and Charlie: Following up on our conversation last week, attached is a high level overview of the CFTC's ability to 

regulate a crypto warehouse. This is isn't written as a brief--it is meant to give you a statement of where the law 

is. Please let me know if you have any questions. 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 5/8/2018 3:29:41 PM 

To: Zaidi, Amir [/o=CFTC/ou=Exchange Administrative Group (FYDIBOH F23SPDLT)/cn=Recipients/cn=azaidi]; Thornton, 

Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Hester Serafini 

[Hester.Serafini@theice.com]; Alex Albert [Alex.Albert@theice.com] 

Subject: Call at 3:45 

Meeting ID: 4005# 

Passcode:i (b)(4) 1 1--·-·-·-·-·-·-·-·-·-·-· 

External numbers: 

us 

Atlanta 1-770-618-8888 

Chicago 1-312-596-4412 

Houston 1-713-815-7276 

New York 1-212-896-2810 

San Mateo 1-650-581-5603 

Trabue Bland 

President, !CE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street, 40th Floor 

Telephone: +1 770.916.7832 (Atlanta) I +1 212.748.4005 (New York) Mo bi I e: 4-·-·-·-·-·-·-·-'(bf (6f ·-·-·-·-·-·-·-·: 

trnbue.b!and@theice.com 

intercontinentalexchange.com 
Message 

From: Alex Albert [Alex.Albert@theice.com] 

Sent: 5/7/2018 8:59:02 AM 

To: Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gill, Michael]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

CC: Trabue Bland [Trabue.Bland@theice.com] 

Subject: RE: Heads up 

Wrapping in Trabue 

From: Alex Albert <Alex.Albe1i(aJtheice.com> 

Date: Monday, May 07, 2018, 8:58 AM 

To: Gill, Michael <MGiWa)CFTC.gov>, 'Thornton, Charlie' <cthomton(a.:CFTC.gov> 

Subject: Heads up 

We need to connect with one of you ASAP. So call Trabue or me back when possible. Thanks 

n-:~:;y conL~ln :_::onfo.t_:,nfr_::~ jr:fot"rn.atbn ~:ind :, ,,.< •. ,; .. ) .• >,; ;',.:; :::::).._:'.._ .. ;-;;:.: ;-;,,c,t""t·c,s; ~.m\_:,Bs e>q>h.::ity noted oih:.:ri.,,.\d::x: y:.::u hi::ve re~{::_;;::n to b::.· i,:.:ve you ~:fft:'. 

i-:·y:;::;::_;i::g::.: n1~1v n::::t r::n>tt:'.:::;::.:ni ::::~1ini::"::n of lnter:_::ontn::.:nt.::! E::x-ch.an:y:.:, in:::. 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 4/19/2018 11:56:52 AM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

CC: Alex Albert [Alex.Albert@theice.com] 

Subject: RE: ICEcryptotimeline2.pptx 

Good question. I was hoping for this week, but maybe next week? 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Thursday, April 19, 2018 11:46 AM 

To: Trabue Bland <Trabue.Bland@theice.com> 

Cc: Alex Albert <Alex.Albert@theice.com> 

Subject: RE: ICEcryptotimeline2.pptx 

WARNING - External email; exercise caution 

Looks good. When do you plan to inform the corn missioners? 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, April 19, 2018 11:39 AM 

To: Thornton, Charlie 

Cc: Alex Albert 

Subject: ICEcryptotimeline2.pptx 

Charlie: 

Sorry to get this to you late, but attached is a proposed timeline for our Crypto launch. I guessed at the 

enhanced scrutiny part. 

Thanks again for your advice. Please let me know if you have any questions. 

Trabue 

unle::_;s ,:.:x-piic:Wv noted oth:.:ri.,,.\d::x: _ if vnu ha'-.:'i.:: rix:;Bon h> tK:lk~'-.:'i.:, are 

i-:·y:;::;::_;i:~g::.: n1~1v n::::t r::n>tt:'.:::;::.:ni ::::~1ini::"::n of lnter:_::ontn::.:nt.:~! E::x-ch.an:y:.:, lp•·: 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 4/7/2018 11:40:41 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Bussey, Brian 

[/o=CFTC/ou=Exchange Admin istrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =a2d0b8b95a0b46029f13 ebead b 73f297-Bussey, Brian]; Za idi, Amir 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi]; Donovan, Eileen A. 

[/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN] 

CC: Kelly Loeffler [Kelly.Loeffler@theice.com]; Mayur Kapani [mayur.kapani@theice.com]; Alex Albert 

[Alex.Albert@theice.com]; Hester Serafini [Hester.Serafini@theice.com] 

Subject: RE: ICE project overview 

Attachments: CFTC_slide_deck040418.pptx 

Great--thank you--here is an updated slide deck. See you Wednesday. 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Friday, April 6, 2018 8:44 PM 

To: Trabue Bland; Thornton, Charlie; Bussey, Brian; Zaidi, Amir; Donovan, Eileen A. 

Cc: Kelly Loeffler; Mayur Kapani; Alex Albert; Hester Serafini 

Subject: Re: ICE project overview 

WARNING - External email; exercise caution 

Trabue 

I think these slides clearly lay out your vision for this project and build upon our previous discussion. Of course, I think 

there will be valuable conversation between the bullet points next week. Look forward to the meeting. 

Charlie 

On: 04 April 2018 10:23, "Trabue Bland" <Trabue.Bland@theice.com> wrote: 

Eileen, Charlie, Brian and Amir: 

Thank you again for speaking with us last week. As we discussed, attached an overview of our project. We 

strongly believe that the CFTC is the best and most qualified regulator for cryptocurrencies and in particular, the 

warehousing of crypto currencies. 

We look forward to seeing you next week, but in the interim, please let me know if you have any questions or 

feedback. Thank you again. 

Trabue 
~!es~~. ~~:xpik~iUy noted oth~~:~\:•,/:s~~: : r y,·)u j·k~V\) re~~~~on t~; t}~~: , ~ .. c.) ):)t. .. · t:re 

:·n~~v net r ~:pre::y~:rn ~n~~: cp) :i.:."n .:.>! jr-:te=-~~crhn~:::nttd Exz)kW\?), 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 3/21/2018 5:33:02 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: RE: Call 

LOL--we just called you!! 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Wednesday, March 21, 2018 5:21 PM 

To: Alex Albert; Trabue Bland 

Subject: RE: Call 

WARNING - External email; exercise caution 

I guess Trabue doesn't like us. 

From: Alex Albert [mailto:Alex.Albert@theice.com] 

Sent: Wednesday, March 21, 2018 4:21 PM 

To: Thornton, Charlie; Trabue Bland 

Subject: RE: Call 

Just remember, I'm for you! 

Trabue, can you do 5? Or tomorrow better? 

From: Thornton, Charlie <cthorntonra)CFTC.gov> 

Date: Wednesday, Mar 21, 2018, 4:17 PM 

To: Alex Albert <Alex.Albert(tzJtheice.com>, Trabue Bland <Trabue.Bland(qltheice.com> 

Subject: RE: Call 

WARNING - External email; exercise caution 

Not Funny. 

From: Alex Albert [mai lto:Alex.Albert@theice.com] 

Sent: Wednesday, March 21, 2018 4:17 PM 

To: Thornton, Charlie; Trabue Bland 

Subject: RE: Call 

Heard you got 400 mil 

From: Thornton, Charlie <cthornton(a).CFTC.gq_y> 

Date: Wednesday, Mar 21, 2018, 4:11 PM 

To: Alex Albert <Alex.Alberticzl.theice.com>, Trabue Bland <Trabue.Bland(al.theice.com> 

Subject: RE: Call 

WARNING - External email; exercise caution 
I am here until the budget comes out. 

From: Alex Albert [mailto:Alex.Albert@theice.com] 

Sent: Wednesday, March 21, 2018 4: 10 PM 

To: Thornton, Charlie; Trabue Bland 

Subject: RE: Call 

Could do call at 5??? 

From: Thornton, Charlie <cthorntonra)CFTC.gov> 

Date: Wednesday, Mar 21, 2018, 4:09 PM 

To: Alex Albert <Alex.Albert(iiltheice.com>, Trabue Bland <Trabue.Bland(qltheice.com> 

Subject: RE: Call 

WARNING - External email; exercise caution 

Was with Mike. Call me now 2.02.-41.8-51.45 . .lust spoke with Chris on this. 

Or we can talk tomorrow. 

From: Alex Albert [mailto:Alex.Albert@theice.com] 

Sent: Wednesday, March 21, 2018 4:07 PM 

To: Thornton, Charlie; Trabue Bland 

Subject: Call 

Charlie, we tried to call you earlier to catch up on things. You got a window tomorrow? 

: · ,,-•,;-:'i-c'~>-· -1'<\· --.>.:I\:~"; ... · ·'., /:·\"·>.·, ·' ~~:fut: n.divn d:~d b. ;~·:k:-n--.k _; -;c~t ~':-~h:•vi~·;(.. ,.,, ... ,n,.,,, .. ,,." ~inif~~~::~. expll~:i-tly n:_:,t(~d c:-t]·~en:·/l~~e. if yt:l; j·~t:\/(: r(~;:~:~iOP to bt:lieo..>(~ '/Oll ~):'(: 

nx;:r;:~it:qt: cn;:~y n:_:,t tt:p:{:-::~.r:r:-t thr: •:;;Din• ;;q '-'' -,:, ,'--.' ,, -,~._.._,..,\, , , --. :-kWiGt•. ltx:: 

~ r:·). h:; ::~.L:b~~jd l;:~de~:; 1 ~~>~ s.., .. ;-: ,~-=--~;~-~.:-~~:~ ,:: i.. .. , .. n :;·:·::~~>~ i..;:· ~FU;::~: ~:·cc U nf;:r:cryph::d '. j:_=;:-c-t:\;r:k:: ff:i:dj l~:; not r;:.: .;~.:, c ,1:1d ;-; :c ; c, .. ; ;:-.) ::-nt of "tj : ~k:~:::::;~.d~Jc ;~-:. 

<:/ tA:!i...·~-~~--~; ~;: --.~\· ;~.;t:: :~~-,:: i\:;-~:l ,.~,::; d ~: -;~ d: ~ ~ \· : u~<:~~- ::~ :'..; ~: c.~~ ~:;~;c ,::de~ t ~,::~,-:!- n·k:~H:r; (/ C'.)tnrr=~~nk:i:(ksn pnv t::::v ;::, hi:•y-:~c-:; : 1dfa-:.d~Jv ;~-:. ~jt::~-:-i. ,.: 

unk::>B expk:iUy nok:d oth.:'r'..:\•t>e. \/OU h~:;\i"e reason t::.; bel\_;:\i"e you ~F,~: 

~t::~;:c~~-t::~ < -~; ~t:: --.~f-;•;~ :;--.~~: i..1"; >=~~:~:i...·--.~~ :;·>:~:::·~<-:::; C.<--.~-; i:W~~y\. jp::: 

[ i. ; , ..... ~ ..:~ ..... ;~}:~:; ...i ;.~_::; ;,;_; ..... ~ 

pj~=;~~~~e dehA~::: :t Hnd n::AJy the ~~.enz:j::.:r. ·r}is tnes~~asr.: n·1t::-/ nc,t tept(~:~~ent the c,pjr-:k::n of lnter::.::c,n~:nentaf j~~:<chanqe, j 1::. .. 

net tr::n~~ti'ute t: ::.::r::r-:~t"~~ct ot qut:Vi~nk~:::. Un::.:nctyph.:d decttGn:::.:: rn~~ij i~~ net s~:::~~ure and Jv: ;-,~:~~ipbnt ei thi~~ n·K:~~.~~w;n 
::::~1hk::n of jnte:· .:t> .:.;~: :-,:>t::d ~:>· ...... \,::.! ~:}:~: 

G::.:'.cUt\:: .~_::nd ·the red~1i::.:'.nt nf ihh; :•-..·; 1:.,-:,·--~~:c 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 3/5/2018 4:47:41 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo] 

Subject: RE: NEWS: Cochran Announces His Intent to Resign from Senate 

Wow. 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Monday, March 05, 2018 4:42 PM 

To: Trabue Bland <Trabue.Bland@theice.com> 

Subject: FW: NEWS: Cochran Announces His Intent to Resign from Senate 

WARNING - External email; exercise caution 

From: Gallegos, Chris (Cochran) [mailto:Chris Galleqos(mcochran,senate.qov] 

Sent: Monday, March 5, 2018 4:40 PM 

Subject: NEWS: Cochran Announces His Intent to Resign from Senate 

FOR IMMEDIATE RELEASE 

March 5, 2018 

CONTACTS 

Chris Gallegos (202) 224-1010 or 224-6414 

Stephen Worley (202) 224-3751 

Twitter: (ii]SenThadCochran 

COCHRAN ANNOUNCES HIS INTENT TO RESIGN FROM SENATE 

WASHINGTON, D.C. - U.S. Senator Thad Cochran (R-Miss.), chairman of the Senate Committee on 

Appropriations, today announced his intention to resign from the U.S. Senate effective April 1, 2018. 

"I regret my health has become an ongoing challenge. I intend to fulfill my responsibilities and 

commitments to the people of Mississippi and the Senate through the completion of the 2018 appropriations 

cycle, after which I will formally retire from the U.S. Senate. 

"It has been a great honor to serve the people of Mississippi and our country. I've done my best to make 

decisions in the best interests of our nation, and my beloved state. My top concern has always been my 

constituents in Mississippi. My hope is by making this announcement now, a smooth transition can be ensured 
so their voice will continue to be heard in Washington, D.C. My efforts, and those of my staff, to assist them 

will continue and transfer to my successor." 

Cochran was first elected to the Senate in 1978, becoming the first Republican in more than 100 years to 

win a statewide election in Mississippi. He is the tenth-longest serving Senator in U.S. history. Cochran 

previously served three terms in House of Representatives. 

### 

LINK 

• Official Cochran Biography: https://w\V\v.cochnm.senate.guv/public/index.cfrn/biographv 

unle::_;s ,:.:x-pk::Wv .1s._n .... :'.·.J :....:U ~'~=~·\·\;...:~,~= ~, • ··vr-.:'i:, t"i:,~:;::_:;on h> bdk~'./i_:, are 

t~·K::>Bi:~:y:.: i·ri~{'i n::::t ;<;:_:pre::_;,:.:ni tK: ::::~1ini::::n of inierc:::::ntni.:,nt.j E:Xchi:~ngi.:,, lp•·: 
Message 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 1/17/2018 2:06:25 PM 

To: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Alex Albert 

[Alex.Albert@theice.com] 

Subject: RE: KC Conference 

Can I make fun of CME? Then I am in. 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Wednesday, January 17, 2018 11:45 AM 

To: Trabue Bland <Trabue.Bland@theice.com> 

Subject: KC Conference 

WARNING - External email; exercise caution 

Talked to Chuck Marvine, we seem to be on the same page as far as you being a panelist at our conference in Kansas 

City. I hope I correctly volunteered your services. 

Charlie 

unk~sB i.:,x~1!i::+\/ nok:d crthet\:\•'~:>e. if y::::u h~1\:,~: n~:i:~:>on to b::_:-l[e;,_,:,~: y;:;u u:·::.: 

i: i'-:'.·~•:>dJ.:..:'. ; , ~.~_::;/ ~ ::.>~ : (:'.); :::;:~::..:-; ,:. l.;;::._;. :):);: i;:.>: i \)," ;; ;t~_::: :..:.<:~ :~i; ,::._;'., kd; ~: .c:..,.'.; i....,, \} ... :'., ; , ;...:.-
Appointment 

From: 

Sent: 

To: 

Subject: 

Attachments: 

Location: 

Start: 

End: 

Show Time As: 

Recurrence: 

Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

3/14/2019 4:39:42 PM 

Kelly Loeffler [Kelly.Loeffler@bakkt.com] 

Accepted: FW: Cal l: Chairman Giancarlo/Bakkt 

invite.ics 

Dial in below 

3/18/2019 4:30:00 PM 

3/18/2019 5:15:00 PM 

Busy 

(none) 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 3/7/2019 3:09:16 PM 

To: Alex Albert [Alex.Albert@theice.com]; Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gil l, Michael]; Trabue Bland 

[Trabue.Bland@theice.com] 

CC: Thornton, Charlie [/o=CFTC/ou=Exchange Admin istrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo] 

Subject: Re: Inter market survei llance meeting 

I grew up listening to them on the way to Destin, FL as a child because they were my parents favorite band. 

On: 07 March 2019 15:05, "Alex Albert" <Alex.Albe1i@theice.com> wrote: 

Fair, but I'm old (saw them a lot in Athens, pre-fame days of '83&'84) and a big fan of 7 Chinese 

brothers. Like them all except for "shiny happy people" which is just a bizarre departure. 

From: Gill, Michael <MGill(«ilCFTC.gov> 

Date: Thursday, Mar 07, 2019, 2:55 PM 

To: Alex Albert <Alex.Albertra)theice.com>, Trabue Bland <Trabue.Bland(a:theice.com> 

Cc: Thornton, Charlie <cthornton(a).CFTC.gov> 

Subject: RE: Inter market surveillance meeting 

\VARNING - External email from cftc.gov 

Come on, i..ifos Rich Pageant is solid from beginning to end. Granted, Fables has its weak moments but I think the Don 

Gehman influence puts Pageant up there with Murmur and Reckoning (and Chronic Town for you purists on album 

counts) 

From: Alex Albert [mailto:Alex.Albert@theice.com] 

Sent: Thursday, March 7, 2019 12:24 PM 

To: Gill, Michael; Trabue Bland 

Cc: Thornton, Charlie 

Subject: RE: Inter market surveillance meeting 

Reckoning 

From: Gill, Michael <MGiWa)CFTC.gov> 

Date: Thursday, Mar 07, 2019, 12:23 PM 

To: Trabue Bland <Trabue.Bland(altheice.com> 

Cc: Alex Albert <Alex.Albert(tzJtheice.com>, Thornton, Charlie <cthorntoniczl.CFrC.gov> 

Subject: RE: Inter market surveillance meeting 

-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-} ; 

Duplicate ; I 

-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·i 
Duplicate 
Duplicate 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/20/2019 6:20:28 PM 

To: Kelly.Loeffler@bakkt.com; Alex Albert [Alex.Albert@theice.com]; Trabue Bland [Trabue.Bland@theice.com]; Mika 

Kawana [Mika.Kawana@theice.com] 

Subject: Agenda 

Attachments: Agenda 2-21.docx 

Here is the agenda for tomorrow. Listing the multiple options is simply to lay out all of the possibilities and to make sure 

that we are all on the same page currently. We can focus on the FCM approach and not the others. Also, the Chairman 

wants NFA to dial-in. 

Happy to chat if you have any questions. 

Best, 

Charlie 
Agenda 

February 21, 2019 

I. Opening 

a. Purpose of this meeting to discuss options for Bakkt' s launch, paths to 

implementation and any potential hurdles, and CFTC "must have" requirements. 

Based on the most recent discussions, the contract approval, trading, and clearing 

of this product is CFTC regulated. It is only the regulatory status of the custody 

of bitcoin that is at issue. 

II. CFTC Requirements 

III. Options for Bakkt launch ,-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· 

IV. Discussion of Timeline 

V. Other Items 

VI.Adjourn 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/18/2019 3:57:17 PM 

To: Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gill, Michael]; Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Gorfine, Daniel 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ cn=fec0394154854e leac5fb409856e5 le8-Gorfi ne, Daniel] 

Subject: Fwd: Agenda 

Attachments: LabCFTCAgenda.docx 

Begin Forwarded Message: 

From: "Alex Albert" <Alex.Albe1i@theice.com> 

Subject: Agenda 

Date: 18 February 2019 15:53 

To: "Thornton, Charlie" <cthornton(al.CFTC.gov> 

Cc: "Trabue Bland" <Trabue.Bland(w.theice.com> 

Charlie, please find enclosed a final agenda for Wednesday's meeting. Please let us know ifwe are missing 

anything or you have other interests while there. We're open to suggestion. Obviously we have flexibility on 

the front and back ends. We'd like to have at least some discussion at the end for process. Thanks, Alex 

unk~sB i.:,x~1!i::+\/ nok:d ::::-ther:.visi.:,. J "/::--;u h~{;,_,:,~: rei:t>on to b::_:-l\_;:\i"s~: y;:;u u:·::.: 

i: i(:'.-~,:>dJ.:..:'. ; , ~.~_::;/ ~ ::.>~ : (:'.); :::;:~::..:-; ,:. l.;;::._;. :):);: i;:.>: i \)," ;; ;t~_::: :..:.<:~ :~i; ,::._;'., kd; ~: .c:..,.'.; i....,, \} ... :'., ; , ;...:.-
Lab CFTC Agenda 

February 20 

10:45 a.m.-11:00 a.m. 

Intro - Bland/Albert/Loeffler [note: KL/AW(?) leaving at 11am for Bakkt board meeting until ~Noon) 

• People in the room 

• Lab CFTC 
i 

: ·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/14/2019 6:45:33 PM 

To: Kulkin, Matthew [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Recip ients/ en =a2d0b8b95a0b46029f13ebead b 73f297-Bussey, Brian] 

CC: Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=3ab6b606c58b45fe8b9174d248b3fa65-Gil I, Michael]; Gorfine, Daniel 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BO HF 23SPDL T)/ cn=Reci pi ents/ cn=fec0394154854e leac5fb409856e5 le8-Gorfi ne, Daniel] 

Subject: Fwd: Trade flows. 

Attachments: Bitcoin Deposit and Trade Flows CFTC v4.pptx; image00l.png 

Begin Forwarded Message: 

From: "Trabue Bland" <Trabue.Bland@theice.com> 

Subject: Trade flows. 

Date: 14 February 2019 18:42 

To: "Thornton, Charlie" <cthornton@CFTC.gov> 

Cc: "Alex Albert" <Alex.Albert@theice.com>, "Erik Haas" <Erik.Haas@bakkt.com> 

Charlie: Hope you are doing well. Following up on our call earlier this week attached is a description of the flows into 

the FCM. I hope this makes sense. Let me know if you have any questions. 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/14/2019 10:59:00 AM 

To: Trabue Bland [Trabue.Bland@theice.com]; Alex Albert [Alex.Albert@theice.com] 

CC: Mika Kawana [Mika.Kawana@theice.com] 

Subject: CFTC / ICE Visit 

We look forward to visiting your headquarters to view your cyber security and other built infrastructure for your Bakkt 

Project. 

We will be available from 10am-3pm on the 20th . Could you please provide an agenda, so that we are prepared for the 

discussion? Also, one of the team members will not be present, so we made need to set up a dial in or video 

conference. We can discuss this later on. 

Thanks! 

Charlie 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/12/2019 12:30:48 PM 

To: Trabue Bland [Trabue.Bland@theice.com]; Alex Albert [Alex.Albert@theice.com] 

Subject: Panel Description 

Futures Trading Matching Algorithms-Alternatives, How They Function, and Effect on Market Performance 

Whereas in pit trading, brokers are able to match orders through face-to-face interactions, an electronictrading environment requires a set of rules that governs the hierarchy for matching buy orders (bids) with sell 

orders (offers) for the purpose of trade execution. Much debate has surfaced about the way that matching 

algorithms could potentially impact individual market participants, as well as overall market performance. This 

session will focus on reviewing the current structures for matching algorithms employed by major exchanges, 

how different orders are prioritized and filled, how the design of the matching algorithms may impact trade 

fills across-the-board or for certain segments of the market, and the ways in which matching algorithms may 

impact overall market performance and efficiency. 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 2/6/2019 5:02:33 PM 

To: Trabue Bland [Trabue.Bland@theice.com] 

Subject: About to call you with mike and others 

Importance: High 

Which phone? 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 12/14/2018 6:38:26 PM 

To: Trabue Bland [Trabue.Bland@theice.com]; Alex Albert [alex.a lbert@theice.com] 

Subject: Fwd: ICE 4(c) Order - StaffTimeline 

Begin Forwarded Message: 

From: "Giancarlo, Chris" <JCGiancarlo@CFTC.gov> 

Subject: RE: ICE 4(c) Order - Staff Timeline 

Date: 14 December 2018 17:27 

To: "Kulkin, Matthew" <MKulkin@CFTC.gov> 

Cc: "Gill, Michael" <MGill@CFTC.gov>, "Sklar, Maggie" <MSklar@CFTC.gov>, "Bussey, Brian" <BBussey@CFTC.gov>, 

"Thornton, Charlie" <cthornton@CFTC.gov> 

Thank you. 

Mike and Charlie - Please inform ICE that this is our current and best estimation. 

JCG 

From: Kulkin, Matthew 

Sent: Friday, December 14, 2018 4:31 PM 

To: Giancarlo, Chris 

Cc: Gill, Michael; Sklar, Maggie; Bussey, Brian 

Subject: ICE 4(c) Order - Staff Timeline 

Mr. Chairman - based on our conversation this afternoon, OCR and DSIO staff are working on the ICE Clear US request 

for a 4(c) order. 

We wanted to share our proposed timeline for completing our work and presenting recommendations to the 

Commission for consideration. 

This timeline assumes that the request from ICE is substantially complete, responsive to staff comments provided a few 

days ago, and that we receive a finalized, formal request from ICE next week. 

Week of December 17 - ICE petition filed 

Week of January 7 - DCR/DSIO staff send draft 4(c) to OGC/OCE for review/feedback, share working draft with Chairman 

Week of January 14 - DCR/DSIO/OGC/OCE complete staff work. Draft order shared with Commissioners; 

Chairman/Commissioner conversations. 

Week of January 21- Order placed into circulation for Commission consideration via seriatim. 

February 5 - open rulemaking meeting 

~February 12 - published in Federal Register 

~March 14 - 30 day comment period closes 

Matthew Kulkin 

Director, Division of Swap Dealer & Intermediary Oversight 

U.S. Commodity Futures Trading Commission 
1155 21st Street:, N\V I Washington, D C 20581 I 202.418.5213 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 6/7/2018 9:55:09 AM 

To: Trabue Bland [Trabue.Bland@t heice.com]; Alex Albert [Alex.Albert@theice.com] 

Subject: RE: Two articl es on the secret SEC effort in crypto 

mmrnrn ... Thanks for sharing. 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, June 7, 2018 9:45 AM 

To: Thornton, Charlie; Alex Albert 

Subject: Two articles on the secret SEC effort in crypto 

As you can see, someone at the SEC is giving someone positive signals here--Goldman (remember that Clayton used to 

represent Goldman) doesn't roll into this stuff randomly! 

https://www,wsj,corn/articles/coinbase-expands-with-deal-for-brnker-dealer-keystone-capital-1528321468 

Goldn1an-backed crypto platfor1n Circle seeks banking license 

Eel Insight 

? June 2018 

373 vvords 

EngHsh 

EJl!'JST 

Copyngi,t 2014 f<ong E:conomic Journal Aii ffoserved 

• 

• 

Cryptocurrency and payments platform Circle Internet Financial plans to seek a federal banking license and also 

pursue registration as a brokerage and trading venue with the US Securities and Exchange Commission (SEC), 

Bloomberg reports. 

Circle, which counts Goldman Sachs among its backers, has had preliminary talks with the US Office of the 

Comptroller of the Currency about obtaining a federal banking license, according to the report. 

Meanwhile, the fintech startup is also said to have some contact with staff at the SEC and officials from the Financial 

Industry Regulatory Authority (FINRA), which oversees brokerages. 
Circle, which ·is headquartered in Bostonr is likely to pursue SEC regulation before the banking license, according to 

the report, which noted that registration with the SEC will allow the platfo,m to sell tokens that are considered 

securities. 

CEO Jeremy Allaire was quoted as saying that with a bank charter, the firm can ho1d customer assets in the form of 

digital coins or government-issued currencies like US dollars. vvhlte opening doors to other components of the 

financial system, such as getting native access to the central banking system withouf intermediaries and directly 

settling with other banks in other markets worldvvide. 

That will help ''improve the efficiency of What we deliver" and can reduce the costs, he said. 

TI1e report noted that while Circle woutd be subjected to tough scrutiny, getting a banking license will narrow the 

field of regulators the firm must appease, as federal laws would pre-empt a patchwork of state rules covering crypto. 

''You're able to have a single conversation. It's hard to have 50 conversations," Robert Bench, chief compfiance 

officer of Circle told Bloomberg, referring to the move that would help cut down on the number of regulators the 

platform needed to work with. 

Coin base, another titan of US cryptocurrency trading, announced on Wednesday that it is acquiring a trio of fo:ms 

including a broker--dealer registered with FINRA. 

It will use licenses it obtains to offer customers blockchain-based securities if US regulators give the nod The 

cryptocurrency trading platform has also broached the topic of a potential banking license with regurators, according 

to Bloomberg sources. 

- Contact us at englisn@,hke(.com 

BN/RC 

Hong Kong Economic Journal Company limited 

Document EJ INST00201806O7 ee6 7000ul 

Trabue Bland 

President1 !CE Futures US 

Intercontinental Exchange I ICE 

55 East 52nd Street, 40th Floor 

Telephone: +i 770.916,7832 {Atlanta) i +1 212,748.4005 (New York) 

Mobile: +l· __ ____ ___ (b){6) _____ ......... i 

trabue.bland@theice.com 

jntercontinentalexchange.com 

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~~.(Oi:lr.t::,Q 'N> _pi10YKW S1l:font.:,l:tciH-ni~~l ~t!!\!!-! ~ n~t PiU~!.W, mu3m,M:S J-t~ir:::1ru!: ()f t~~t:,o--HJl'~;..\4;~;t}t1 ~ •. vhere r-tr•,ttr.y C)t ~.i Clh'K'.fh•r;~ 1-'~~l~f;~ l:;. +:f:~:$H:er 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 5/31/2018 9:57:30 AM 

To: Trabue Bland [Trabue.Bland@theice.com]; Alex Albert [Alex.Albert@theice.com] 

Subject: Number for today at 11:30 

1-866-617-3597 

ParticipantPasscode:j {b){4) I 

'-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· . 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7C01B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 5/21/2018 3:36:15 PM 

To: Zaidi, Amir [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/ cn=Recipients/cn=azaidi]; Donovan, 

Eileen A. [/o=CFTC/ou=Washington, DC/cn=Recipients/cn=EILEEN DONOVAN); Bussey, Brian [/o=CFTC/ou=Exchange 

Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f 13ebeadb73f297-Bussey, Brian]; 

Kuserk, Gregory [/o:cCFTC/ou=Washington, DC/ cn=Recipients/cn=gkuserk); Leahy, Thomas M., Jr. 

[/o=CFTC/ou=Washington, DC/cn=Recipients/cn=tleahy]; Van Wagner, David [/o=CFTC/ou=Washington, 

DC/cn=Recipients/cn=dvanwagner); Gorfine, Daniel [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOH F23SPDL T)/cn=Recipients/cn=fec0394154854e l eac5fb409856e5 le8-Gorfi ne, Daniel]; Raimondi, Phi Ii p 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Raimondi, Philip490] 

CC: Sklar, Maggie [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=ReclpJents/cn=Sklar, 

Maggieca3); Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=3ab6b606c58b4Sfe8b917 4d248b3fa65-Gil I, Mi cha el] 

Subject: RE: Warehouse legal overview 

.-·-·· <-·-·-·-•-1-•-•-·-·-·-- ·-·-·-· .. ·-·-·-·-·-·-· . ' ' I Non-Responsive l "

! 

-•-·-·-·-·-·-·-·-•-·-·-·-·-·-·-·-•-· .. ,- ,_,_,_,_,_,_,, 

~ 

From: Zaidi, Amir 

Sent: Monday, May 21, 2018 3:27 PM 

To: Thornton, Charlie; Donovan, Eileen A.; Bussey, Brian; Kuserk, Gregory; Leahy, Thomas M., Jr.; Van Wagner, David; 

Gorfine, Daniel; Raimondi, Philip 

Cc: Sklar, Maggie; Gill, Michael 

Subject: RE: Warehouse legal overview 

! · 

-·-·-·-·-·-·-·-·-·-· ---

Non-Responsive I -·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-•.J' ----- '-·-·-·-·-·-·-·-·-···-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· -·-·-·-·-·-·-·-·-·-·---·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·---·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·---·-·-·-·-·-··-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· ------------------------------·-- ---------------------------------

From: Thornton, Charlie 

Sent: Monday, May 21, 2018 3:22 PM 

To: Zaidi, Amir; Donovan, Eileen A.; Bussey, Brian; Kuserk, Gregory; Leahy, Thomas M., Jr.; Van Wagner, David; Gorfine, 

Daniel; Raimondi, Philip 

Cc: Sklar, Maggie; Gill, Michael 

Subject: RE: Warehouse legal overview 

r--··-·-·-·-·-·-·-·-·--··-·· '-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· , ·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·- -·-·-·-·-·· --·-·-·-·-·-·-·-·-·-·-·· , -·-· , ·-·-- ·-·-·-·-·-·-·-·-·-·-·--··-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-' ·-·-, ··-· --·-·1 

i i 

; 

; 

; 

i 

; 

; 

; 

; 

; 

! 

; 

; 

; 

; 

; 

; 

; 

! 

;·--·--

It 

l 

Non-Responsive ~ ·--·--·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-··-·-·-·--·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-··-·-·-·--·-·-·-·-·-·-·-·-·-·-·-··-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·--·J 

··· ····· ····· ··· - ·•--'-----

From: Zaidi, Amir 

Sent: Tuesday, May 15, 2018 3:47 PM 

To: Donovan, Eileen A.; Bussey, Brian; Kuserk, Gregory; Leahy, Thomas M., Jr.; Van Wagner, David 

Cc: Thornton, Charlie 

Subject: FW: Warehouse legal overview 

All, 
Non-Responsive 

From: Trabue Bland [mailto:TrabueJ31and@theice,com] 

Sent: Tuesday, May 15, 2018 10:20 AM 

To: Zaidi, Amir; Thornton, Charlie 

Subject: Warehouse legal overview 

Amir and Charlie: Following up on our conversation last week, attached is a high level overview of the CFTC's ability to 

regulate a crypto warehouse. This is isn't written as a brief--it is meant to give you a statement of where the law 

is. Please let me know if you have any questions. 

pl~:::~~~~e dehA~::: :t Hnd n::.tJy the ~~.enzk:t. Thi~~. rn::.:s~~aq::.: n·k(/ not repn~:~~ent the op!~ k;n of intet::.>:)n~:n::.:ntai i~~xch~~n9e, i ~::.-. 

net tr::n~tH'ute t: ::.::r.::n~t'~~ct ot qut:Vi~nk~:::, Un::.:nctyph.:d dect:\)n:::.:: rn~~il i~~ net s~:::~~u e an::J ~rv: r,~:~~ipl~:::nt ci thi~~ n·K:~~.~~w;n 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 4/19/2018 11:58:40 AM 

To: Trabue Bland [Trabue.Bland@theice.com] 

CC: Alex Albert [Alex.Albert@theice.com] 

Subject: RE: ICEcryptotimeline2.pptx 

Sounds good. Let's hop on a call to discuss the timeline. I have a few questions. In and out of meetings today on the 

Hill, but let me know when works for you all. 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, April 19, 2018 11:57 AM 

To: Thornton, Charlie 

Cc: Alex Albert 

Subject: RE: ICEcryptotimeline2.pptx 

Good question. I was hoping for this week, but maybe next week? 

From: Thornton, Charlie [mailto:cthornton@CFTC.gov] 

Sent: Thursday, April 19, 2018 11:46 AM 

To: Trabue Bland <Trabue.Bland@Hheice.com> 

Cc: Alex Albert <Alex.Albert:(Wtheice.com> 

Subject: RE: ICEcryptotimeline2.pptx 

WARNING - External email; exercise caution 

Looks good. When do you plan to inform the commissioners? 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, April 19, 2018 11:39 AM 

To: Thornton, Charlie 

Cc: Alex Albert 

Subject: ICEcryptotimeline2.pptx 

Charlie: 

Sorry to get this to you late, but attached is a proposed timeline for our Crypto launch. I guessed at the 

enhanced scrutiny part. 

Thanks again for your advice. Please let me know if you have any questions. 

Trabue 

unle::_;s ,:.:x-piic:Wv noted oihen:vk;e_ if vnu ha'-.:'i.:: rix:;Bon h> tK:lk~'-.:'i.:, are 

1~·1::.:;::;::_;i:~g::.: n1~1v n::::t r::n>tt:'.:::;::.:ni ::::~1ini::"::n of lnter:_::ontn::.:nt.:~! E::x-ch.an:y:.:, lp•·: 

,:;.:~~[), :~:::, -~•~.,:)v'.J\LL>~: :·1nt :_::::::n:::;ttuie ~~ :_::::::n·truct !.:'it :_:u~:;runtee, l t'Y:nc:rypk::_:i s:_+:_x:irnni::: rr:aH :·1nt :>tx~ure ~:ind tht:'. re::~ipknt :>f P'~~.:y::z:-:y~ ::::; 

e::<p:.:ct::.:d to pn>;,_,:kk ::.;i:dt:'.9~t:u-dB ft\>:·n ;,_,:i:·i ;.::_~::.., . ._1•-.., ,,._.·"'~,::..~ : ·\~•,-.. :~::..--- ., ... , ~i· ._-:; ~"' ...... ," ,, ... ~,·, ~ .... 1~ ~"' 1.; '"'::..~ s:..' ,-.. , : 1-: ._-..· ..... i , ... i ·} • '::..~::..,;. ..... :::> ... ;. ,,, ;. ·::..--- ... ~ 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 4/19/2018 11:44:23 AM 

To: Trabue Bland [Trabue.Bland@t heice.com] 

CC: Alex Albert [Alex.Albert@theice.com] 

Subject: RE : ICEcryptotimeline2.pptx 

Thank you. I will review! 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Thursday, April 19, 2018 11:39 AM 

To: Thornton, Charlie 

Cc: Alex Albert 

Subject: ICEcryptotimeline2.pptx 

Charlie: 

Sorry to get this to you late, but attached is a proposed timeline for our Crypto launch. I guessed at the 

enhanced scrutiny part. 

Thanks again for your advice. Please let me know if you have any questions. 

Trabue 

i.d ~;,>~~-~-=- t::.<~:h"\;/: (A-;;:d ofr~t::r\\·'~:~~-t::. j-~ yo~ j-~tf,/~~ t~~a~~'.)P tc: bt::Ue,.,~~ you t:r-;;: 

~t::~;:,>~~-t::~ < -~; ~t:: --.:f-;•;~ :;--.:~: d-; >=~~:~:~.---.:~ :;·~~:~:::·~<,::; C.< ... ~-; tff~~Y\- ~nc: 
Appointment 

From: 

Sent: 

To: 

Subject: 

Attachments: 

Location: 

Start: 

End: 

Show Time As: 

Recurrence: 

Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

3/28/2018 10:16:33 AM 

Trabue Bland [Trabue.Bland@theice.com] 

Accepted: FW: Cal l with the CFTC 

invite.ics 

Dial in below 

3/28/2018 11:00:00 AM 

3/28/2018 12:00:00 PM 

Busy 

(none) 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 3/21/2018 5:40:53 PM 

To: Trabue Bland [Trabue.Bland@theice.com] 

Subject: FW: White House opposed Republican picked to replace Cochran 

From: POLITICO Pro [mailto:politicoemail@politicopro.com] 

Sent: Wednesday, March 21, 2018 12:10 PM 

To: Thornton, Charlie 

Subject: White House opposed Republican picked to replace Cochran 

White House opposed Republican picked to replace Cochran 

By Alex Isenstadt 

03/21/2018 12:06 PM EDT 

White House officials this week told Mississippi Gov. Phil Bryant that President Donald Trump did not plan to 

campaign for or endorse Republican Cindy Hyde-Smith if she was appointed to the state's open Senate seat, 

saying they were worried that the former Democrat would lose. 

Bryant responded that he intended to go ahead and pick Hyde-Smith for the post, anyway. He's expected to 

formally announce the selection Wednesday. 

During a phone call Tuesday, administration officials told Bryant that Hyde-Smith's past history as a Democrat 

would hobble her in the special election contest for the seat being vacated by longtime Republican Sen. Thad 

Cochran. Hyde-Smith switched parties in 2010 while serving in the state Senate. 

The conversation was described by two White House aides with direct knowledge of the call. 

The message underscored the profound misgivings the administration and senior Republicans have about the 

Hyde-Smith pick. 

Republicans are deeply concerned that Chris McDaniel, an anti-establishment conservative state senator who is 

running for the seat, will use Hyde-Smith's past party affiliation against her in the race. In recent days, the 

White House and other senior Republicans reviewed polling conducted by the National Republican Senatorial 

Committee showing Hyde-Smith in third place in a prospective match-up, trailing McDaniel and a prospective 

Democratic candidate. 

A spokesman for the governor, Clay Chandler, would only say that, "Gov. Bryant isn't going to respond to leaks 

from unnamed sources in Washington." 

"Today is about Mississippi making history, and Commissioner Cindy Hyde-Smith becoming Senator Cindy 

Hyde-Smith when she is sworn in by Vice President Mike Pence," he added. 

Hyde-Smith and the NRSC did not respond to requests for comment. 
Trump had initially lobbied Bryant to appoint himself to the seat, but the governor declined. Many in the party 

had hoped that Bryant would select Mississippi Secretary of State Delbert Hosemann for the post. The White 

House has been in touch with the governor over the course of the past three weeks about his selection. 

While the president does not currently plan to endorse Hyde-Smith, the White House will continue to monitor 

the race, one of the administration officials said. 

Administration officials do not want Trump to embarrass himself by weighing in for a candidate who is 

seriously hobbled. It was a scenario that played out in last year's Alabama Senate special election, when the 

president got behind appointed Sen. Luther Strange in a GOP runoff, only to see him fall short against former 

state Supreme Court Justice Roy Moore. 

White House aides briefed Trump on Tuesday prior to speaking with Bryant. They recommended that, for now, 

the president should not endorse or campaign for Hyde-Smith should she get the appointment. Trump, 

according to one person familiar with the conversation, did not object. 

To view online: 

https :/ hNW\V. politico pro. com/budget::-J:tppropriati ons/ aiii cl e/2018/03 /white-house-opposed-republican-picked-toreplace-cochran-4 77 5 71 

Was this Pro content helpful? Tell us what you think in one click. 

~ ~ CJ 

Somewhat = Not really Not at all 

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Appropriations: all stories. To change your alert settings, please go to 

https ://www .politicopro.com/settings 

LJ 

This email was sent to cthomton@cftc.gov by: POLITICO, LLC 1000 Wilson Blvd. Arlington, VA, 22209, 

USA 
Message 

From: Thornton, Charlie [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=2F7CD1B27F3E4FDE80A5088EADD3B931-THORNTON Ill, NORWO] 

Sent: 1/17/2018 11:45:00 AM 

To: Trabue Bland [Trabue.Bland@theice.com] 

Subject: KC Conference 

Talked to Chuck Marvine, we seem to be on the same page as far as you being a panelist at our conference in Kansas 

City. I hope I correctly volunteered your services. 

Charlie 
Appointment 

From: Mika Kawana [Mika.Kawana@theice.com] 

Sent: 3/6/2019 1:59:48 PM 

To: Gorfine, Daniel [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Admin istrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd l b27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Kelly Loeffler 

[Kelly.Loeffler@bakkt.com]; Trabue Bland [Trabue.Bland@theice.com]; Adam White [adam.wh ite@bakkt.com]; 

Saverson, La Shunda [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Saverson, 

La Shundae98]; Alex Albert [Alex.Albert@theice.com] 

Subject: Meeting: Daniel Gorfine & Charlie Thornton I Kelly Loeffler, Trabue Bland, Alex Albert & Adam White 

Location: BR Resort I Vidal Meeting Room - Tower Building I Ground Floor 

Start: 3/12/2019 9:00:00 AM 

End: 3/12/2019 9:30:00 AM 

Show Time As: Tentative 

Recurrence: (none) 

3.6-shortened to 9:00a-9:30a 

pj~:::~~~~e dehA~::: :t Hnd n::AW/ the ~~.enz:je:·, Thi~~- rn::.::~:~~a9e n·k(/ not repn~:~~ent the opj~ ;u~··: u; ;) =·~~:::=, ... ,•.;: ._ ,::.~··, ❖·:) =·:. <t ~>~:\;(', = ~::.-. 

net tr::n~tH'ute t: ::.::r.::n~t'~~ct ot qut:Vi~nk~:::. Un::.:nctyph.:d dect:\)n:::.:: rn~~il i~~ net s~:::~~u e an::J ~rv: r,~:~~ipl~:::nt ci thi~~ n·K:~~-~~w;n 
Appointment 

From: Mika Kawana [Mika.Kawana@theice.com] 

Sent: 3/5/2019 9:14:43 AM 

To: Gorfine, Daniel [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Trabue Bland 

[Trabue.Bland@theice.com]; Saverson, La Shunda [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=Saverson, La Shundae98]; Alex Albert [Alex.Albert@theice.com] 

Subject: Meeting: Daniel Gorfine & Charlie Thornton I Kelly Loeffler, Trabue Bland, Alex Albert & Adam White 

Location: BR Resort I Vidal Meeting Room - Tower Bu ilding I Ground Floor 

Start: 3/12/2019 9:00:00 AM 

End: 3/12/2019 10:30:00 AM 

Show Time As: Tentative 

Recurrence: (none) 
Appointment 

From: Gill, Michael 1/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=3AB6B606C58B45FE8B9174D248B3FA65-GILL, MICHAEL) 

Sent: 2/21/2019 7:31:16 PM 

To; Giancarlo, Chris [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Giancarlo1 

Chds2a4); Kelly Loeffler [Kelly.Loeffler@theice.com]; Bussey, Brian [/o=CFTC/ou=E.xchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Zaidi, Amir 

1/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi); Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kulkin, Matthew]; Sklar, Magg1e 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipient s/cn=Sklar, Maggieca3]; Thornton, 

Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo); Alex Albert 

[Alex.Albert@theice.com]; Trabue Bland [Trabue.Bland@theice.com] 

Subject: CFTC warehouse review call 

Location: Dial-in: 866-564-2207 Participant Cod el_ (b )( 4 )__! 

Start: 2/28/2019 8:00:00 AM 

End: 2/28/2019 9:00:00 AM 

Show Time As: Tentative 

Required Giancarlo, Chris; Kelly Loeffler; Bussey, Brian; Zaidi, Amir; Kulkin1 Matthew; Sklar, Maggie; Thornton, Charlie; Alex 

Attendees: Albert; Trabue Bland 
Message 

Sent: 10/12/2018 11:40:29 AM 

To~ Zaidi, Amir [/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi]; Bussey, 

Brian [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOH F23SPDL T)/cn=Recipients/cn=a2d0b8b95a0b46029fl3ebeadb 73f297-Bussey, Brian); Kulkin1 Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kulkin, Matthew] 

CC: Gill, Michael [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=3ab6b606c58b45fe8b9 l 7 4d248b3fa65-Gil I, Mi cha el]; Sklar, Maggie 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Sklar, Maggieca3]; Jones, 

Shonneice 1/OccCFTC/OU=Washington, DC/cn=Recipients/cn=sknight] 

Subject: FW: DRAFT Bitcoin Submission 18-XXX.docx (002).doc 

Attachments: DRAFT Bitcofn Submission 18-XXX.docx (002).doc 

, ......... -... , .............................................................................................................. , ,.,, .. , ... -......... , .. , ........ , .. , ................................... ~,--. ---·--- ----·-·-·-·-·-·-·-·-··· ...................................... ~---·-·-·-·-·-·--·--·- ; 

Non-Responsive 

I .-•-•-l--•-·--·-·-•-·-- ·-1-, ·-·- ·-·-•- .-•-•-I--•- ·--•-·-•-·-•-·-·-·-· . ·--•-·-•-•-l--•-·--·-·-•-~-·-1-. ·-·- ·-- •- .-•-•-l--•- ·--·-·-•-•-.-• ·- •-l---•-- •- .-•-•-l--.- ·--·-·-•-·--·-1-.-·-·-·-·-•- .-•-•-l--•- ·--•-·-•-·-•-· ·- •-l---·--•-·-•-·-- - · . . 

From: Trabue Bland [mailto:Trabue.Bland@theice.com] 

Sent: Friday, October 12, 2018 11:29 AM 

To: Thornton, Charlie; Bussey, Brian; Zaidi, Amir; Kulkin, Matthew 

Cc: Eamonn Hahessy; Hester Serafini; Audrey Hirschfeld; Alex Albert 

Subject: DRAFT Bitcoin Submission 18-XXX.docx (002).doc 

Charlie, Brian, Amir and Matt: 

Attached is a revised draft DCM submission for the physically delivered BTC future. The changes are mainly 

technical with exception of the discussion of our trading and clearing firm feedback. You should be receiving draft rules 

from ICUS shortly and answers to your questions from a few weeks ago. 

Thank you again for your review. Please let me know if you have any questions. 

Trabue 

Trabue Bland 

President, ICE Futures US 

Intercontinental Exchange I JCE 

55 East 52nd Street, 40th Floor 

Telephone: +1 770.916.7832 (Atlanta)! +1 212.748.4005 (New York) 

Mobile: -t[ (b)(6) . . i 

trabue,bland@thelce,com 

intercontinentalexchange.com 

I I I I CI: C ::: 1:: I: m1::11:::11::111:1ca: C :: I : I: CI: C ::: 1:: I: CI I I I ::11::111:1m 1::1 ::: 1:: I IC I: C : Ii :a1 : I: 1:: I I 1·1 ::c ::c 1:: I IC I: C ::: c:111:1m 1::11:::11:: I I c·1: C ::c ,:: I IC I: C ::: 1:: arna:11::11:::11::11 ::c I: C :: 1:: I IC I: C ::: 1:: I I en : CI C I:. 
;::;::_:'.(/Jt"i_:, .~.:~nd ·the red~1i::_:'.nt nf ihh; :·---·; 1:.,-:,·--~~:c 

: · >>,s:-c ... /~ j::::; :_:k:;::;lred 
Appointment 

From: Erik Haas [Erik.Haas@bakkt.comJ 

Sent: 2/13/2019 9:42:38 AM 

To: Erik Haas [Erik.Haas@bakkt.com l; Hester Serafini [Hester.Serafini@theice.com ]; Trabue Bland 

[Trabue.Bland@theice.com]; Alex Albert [Alex.Albert@theice.com]; Donovan, Eileen A. [/o=CFTC/ou=Washington, 

DC/cn=Recipients/ cn=EILEEN DONOVAN); Bussey, Brian [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian): KUlkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/ cn=Recipients/ cn=f973c0fe038 7 42b4bb68c3eeae3 f8171-Ku !kin, Matthew]; David Clifton 

[David.Clifton@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDL T)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, Norwo]; Beale, Joshua 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=Beale, Joshua742]; Gorfine, 

Daniel [/o=CFTC/ou=EXchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=fec0394154854eleac5fb409856e51e8-Gorfine, Daniel] 

Subject: CFTC/Bakkt/lCUS 

Location: Dial in below 

Start: 2/13/2019 4:00:00 PM 

End: 2/13/2019 5:00:00 PM 

Show Time As: Busy 

Recurrence: (none) 

Continued conversation from 2/12 call including Hester Serafini. 

Internal extension: 8888 

Meeting ID:. 6733# ·-···-···-···-··, Password: L._ ____ __ _(b )( 4) _________ _! 

Atlanta +1 770 618 8888 

Chicago +1 312 596 4412 

Houston +1 713 815 7276 

New York +1 212 896 2810 

San Mateo +1650581 5603 

Phoenix +1 480 444 0215 

Trui r~~~;ssg~ n'111y e;o~t.::ir; ::ont:;j~n!;E{ :nt<m'f'sticn in<1 ~~: :nt~10~~1 :or ~;i~Cif it recip:snts uniest- -9M}HOlfh/ ~otn-~ t>tner.}::a€ :r v·c~A ?)~vr: M;-~i-er:. i,~ ~eHev~ voG :m-e 

net an 1~t~1.~1d*ri re::i0k~?1t 0f thjfi n:~:-sr)~&: f)1e,.,7:n~ :.ie}~.h1 it ~nC t¥;hf-/ the ~~nd~r. Th5 r:1w~£:-3⁄4~g~ tr~~1f net !-?::prener:t !?":~ {.">Pl°n~ch r;.f 1nte'rr .. c~t1t,e~t~~ :'::¥"~h~-lr:!}f;! ~n~:... 

ttCf::)! ITT1 sut~t:fan~-=; ,0r ~ffi}i,1:vts. and .qoe~~ net cc~"'rtit(:1-e ,1. ~cr~·::rnc? or 9:.k1'rante~ Un!~nC!"/p.t~d-ntec!~in!::.. n~aa ~:-nci {}8:;;.Jm Bn<l ;he rt~dpfsnt of!~is n,~ .. f:.t;;1ge f~i 

t:\ Nt!•Ni to t1rc~i<W sat~~f~t!-:s.ftoro vih.J~en ,nn(i purtue sR~~u~ ~e!1⁄4rm. of r...arn!r:Ltnir.,s-~~on~A-'h~re priY::1•~Y or :c1. tH~r:J tn~n~d~:ftS l~-(Je:;:i!:'fl'(t 
Appointment 

From: Christina Canfield [Christina.Canfield@bakkt.com) 

Sent: 2/12/2019 9:04:12 AM 

To: Chdstina Canfield [Christina.Canfield@bakkt.com]; Kelly Loeffler [!<elly.Loeffler@bakkt.com]; Trabue Bland 

[Trabue.Bland@theice.com]; Alex Albert [Alex.Albert@theice.com]; Erik Haas [Erik.Haas@bakkt.com]; Adam White 

[adam.white@bakkt.com); David Clifton [David.Clifton@theice.com]; Geoffrey.Goldman@Shearman.com; Bussey, 

Brian [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian); Kulkin, Matthew 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOH F23SPDLT)/ cn=Recipients/ cn=f973c0fe0387 42b4bb68c3eeae3 f8171-Ku I kin, Matthew] 

CC: Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton Ill, NorwoJ; Beale, Joshua 

[/o=CFTC/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn-=Beate, Joshua742) 

Subject: Call; CFTC/B;ikkt Discussion 

Location: Dial in below 

Start: 2/12/2019 4:00:00 PM 

End: 2/12/2019 5:00:00 PM 

Show Time As: Tentative 

Internal extension: 8888 

Meeting ID: 4726# 

Password:! (b)(4) i 

Atlanta +1 770.618.8888° 

Chicago +1 312 596 4412 

Houston +1 713 815 7276 

New York +1 212 896 2810 

San Mateo +1 650 581 5603 

Phoenix +1 480 444 0215 

TT)m :YWt'iSJ.hJi:; fr:a, t>~~1t}rt; , ~~t'=-tid;,~nfo;:~ inforrn;;:tk)i"l' i:HW !';.. :,~·t:N)G~~1 icr 'i!>~c-11}~ ro-cm~tv1U.> un!eij'>- •~~plicitiv ~1<1te-(t t'trto.;.>r~l~~,0 =i y<J-i=J ~1,TT~'::" t;:"~w..;pti..1 ~die'v'e you /!H'i:' 

1~:;i .m1 H,1r:;r;d0C tt-~Jt}:{?:it .;.;.r· t?,11:; :rv~J<:;J}~f p:i3⁄4i~~e di~kt~ 1f ~1nc n~:1,:1y tr~ ~J~~rh:ie.•r "ff-it$ ,-:-)!~m:;f~•:! ~ni;;y i':l{>t :r~r,1~:iw~ ... v.1t i?1i:: op.=r;101~ of fr:te:-·:~oc;jnii•nis:t E >:(~?uin~tf:' ~ lfv.: .. 

1 t(;E): ITT,. ij:Jb&=~~~lf1';~'i or affr:k1tr:.•!..t and ~o.,:.~~ l:ct 1.;o!~~t=!ut-11 a coptr:ac.f 1.>r ~uara~t'C'{~ -U-ff·:;n,~y-pt!i•~l --',H-<Jd:'t;:,ni;-, !'f':.;,U: i~ '::d $-evun.:- ~:rH.f ~tie n.:"Gl~}={?:~t ~A 1~1,s. n~~>~gt~ i-;. 

~,"<Pi:!'ct0-t; to t.:·:"()Ytde !;?J~:~;:.tt~idG v.-,~, ,;:!tJ::,i:'li <lf':<.i p:&-1!1-Ui) dUJ>tr1tiit: :ni:;fans of comn·:un1t~1;~:>n · .. ,vh~)H; ,J'>r~\1⁄4!t£;.j ot a- ~tndh'1t;i :<r\e'~t~ag.t:- l::t dr:t,;iF.:d 
Appointment 

From: Kulkin, Matthew [/O=CFTC/OU=EXCHANGE ADMINISTRATIVE GROUP 

(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=F973COFE038742B4BB68C3EEAE3F8171-KULKIN, MATTHEW] 

Sent: 2/6/2019 10:31:24 AM 

To: Kulkin, Matthew [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=f973c0fe038742b4bb68c3eeae3f8171-Kul kin, Matthew]; Thornton, Charlie 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Recipients/cn=2f7cd lb27f3e4fde80a5088eadd3b931-Thornton 111, Norwo ]; Bussey, Brian 

[/o=CFTC/ou=Exchange Administrative Group 

(FYDIBOHF23SPDLT)/cn=Recipients/cn=a2d0b8b95a0b46029f13ebeadb73f297-Bussey, Brian]; Trabue Bland 

[Trabue.Bland@theice.com] 

Subject: Ca ll 

Attachments: invite.ics 

Start: 2/6/2019 11:00:00 AM 

End: 2/6/2019 11:30:00 AM 

Show Time As: Tentative 

Recurrence: (none) 

When: Wednesday, February 06, 2019, 11 :00 AM to 11:30 AM. Eastern Time 

Where: 
Appointment 

From: Trabue Bland [Trabue.Bland@theice.com] 

Sent: 3/28/2018 10:01:31 AM 

To: Trabue Bland [Trabue.Bland@theice.com]; Thornton, Charlie [/o=CFTC/ou=Exchange Administrative Group 

(FYDI BOHF23SPDL T)/cn=Redpients/cn=2f7cdlb27f3e4fde80a5088eadd3b931-Thornton 111 1 Norwo]; Zaidi, Amir 

[/o=CFTC/ou=Exchange Adtninistrative Gr'OL!P (FYDIBOHF23SPDLT)/cn=Recipients/cn=azaidi) 

Subject: FW: Call with the CFTC 

Location : Dial in below 

Start: 3/28/2018 11:00:00 AM 

End: 3/28/2018 12:00:00 PM 

Show Time As: Busy 

Recurrence: (none) 

From: Trabue Bland <Trabue.Bland@theice.com> 

When: Mar 28, 2018 at 1 I :00 AM 

Subject: Call with the CFIC 

Location: Dial in below 

Dial-in: 8888 (Or external number be.low) 

Meeting ID: 4005# 

Passcode:t (b){4) 7 

External n'umbers: 

us 

Atlanta 1-770-618-8888 

Chicago 1-312-596-4412 

Houston 1-713-815-7276 

New York 1-212-896-2810 

San Mateo 1-650-581-5603 

Thn~ :'flr:~w.~vJ,~~ n:n:y c<J~tt·~m t,\)11id~nfo;;f irlor:'l'1;;:Ucn -1.:\nd t~ :r=t,'-1)(.;etl f~;r ~~:,i.:.cd~. r:;-~plfti~ t.r.\t{~J\ ~J;:(t)Hi~tt;y-NJt-~tl ,-t~~-.:.:n,~,i~~ J Y,f:!~~ hS:\<{:' n;'a~~)t~ to b~·he-...1~ vou .i;tri:i 

l'1Y~ .an rn1:;-n;.i~.:'1C R:'~f;)r:1~1r Qf int~ trwr.J.-se~~. p:i?t:i~ d1:;kk? H ~=-~ \" {::!:i't tl~•e :t~..:n(h~r ff)is ~':"i~;i;;;:g::! rnay r~ot ~:::':l)rH~¥i.•-nt thf.-! -c;.w1:=;)t~ ,.>f 1nt-1J:'CO{~?:in:i.•nt~;~ £),;C~lBnfr~~ int,, 

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t"'X~Eit,tr;~ t{} .p:'t)Y~<Jt:. t E:f?g,~.!fds ir:;,rn ~1~1i,~:s.eit; Qt':\1 p!/f~'-14?' s:}tHrm..1-h.?" l'iWJ:.:\r:s of ,::armnunit}~1tkill whtN"? J):~v>.:K'f- Of i~ P1.qrJir.9 1fti)t?~{~Q(?t k: d~fi·cd