UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

STATION PLACE 100 F STREET, NE WASHINGTON, DC 20549-2736 Office of FOIA Services

May 24, 2011

Mr. Michael Brozzetti Boundless LLC 3513 Bowman Street Philadelphia, PA 19129 Re: Freedom of Information Act (FOIA), 5 U.S.C. 552 Request No. 11-06336-FOIA

Dear Mr. Brozzetti: This letter refers to your request, dated April 29, 2011 and received in this office on May 3, 2011, for a summary of all reported incidents and opinions, including concurring and dissenting opinions, as well as orders, made in connection with the adjudication of matters relating to the Canon of Ethics, the Standards of Ethical Conduct for Employees of the Executive Branch and other Related Statutory Authorities (collectively the Code of Ethics) from 2006 to Present. In addition, you seek for each Commission employee, a signed acknowledgment to the Code of Ethics. Under the Freedom of Information Act (5 U.S.C. 552 (a)(6) and 17 CFR 200.80(d)(5)-(7)) the Commission must determine within 20 business days after the receipt of the request whether to comply with such request and notify the requestor of the decision. This letter is to notify you that your request is being processed. We will not be able to complete the processing of your request within this timeframe due to the need to search for and collect the requested records from field facilities or other establishments that are separate from this office. As soon as any responsive records are received from the appropriate office, I will review the records and provide further response to your request within 30 working days. If you would like to modify your request to enable us to respond within a shorter time frame, or if you would like to arrange an alternative time frame for the processing of your request, please contact me as soon as possible.

Mr. Michael Brozzetti May 24, 2011 Page 2

11-06336-FOIA

Regarding your request for a fee waiver, this office may waive or reduce search, review, and duplication fees if (A) disclosure of the requested records is in the public interest because it is likely to contribute significantly to public understanding of the operation or activities of the government and (B) disclosure is not primarily in the commercial interest of the requester under 17 CFR 200.80 e)(4). This office will determine whether disclosure is likely to contribute significantly to public understanding of the operations or activities of the government based upon four factors: Whether the subject matter of the requested records concerns the operations or activities of the Federal government; Whether the requested records are meaningfully informative on those operations or activities so that their disclosure would likely contribute to increased public understanding of specific operations or activities of the government; Whether disclosure will contribute to the understanding of the public at large, rather than the understanding of the requester or a narrow segment of interested persons; and Whether disclosure would contribute significantly to public understanding of the governmental operations or activities.

This office will determine whether disclosure of the requested records is not primarily in the commercial interest of the requester based upon two factors: Whether disclosure would further any commercial interests of the requester; and Whether the public interest in disclosure is greater than the requester's commercial interest under 17 CFR 200.80 (e)(4)(ii).

Mr. Michael Brozzetti May 24, 2011 Page 3

11-06336-FOIA

While SEC grants waivers of FOIA fees where appropriate, we are also obligated to safeguard the public treasury by not granting waivers except as provided by the FOIA. As a requester, you bear the burden under the FOIA of showing that the fee waiver requirements have been met. Based on my review of your letter of April 29, 2011, and the applicable fee waiver criteria, I have determined that your request is deficient as it does not provide substantive information relating to any of the six factors. Your request for a fee waiver is consequently denied. You have the right to appeal our determination to deny your request for a fee waiver, to our General Counsel under 5 U.S.C. 552(a)(6), 17 CFR 200.80(d)(5) and (e)(4). Your appeal must be in writing, clearly marked "Freedom of Information Act Appeal," and should identify the requested records. The appeal may include facts and authorities you consider appropriate. Send your appeal to the FOIA/Privacy Act Office of the Securities and Exchange Commission located at Station Place, 100 F Street NE, Mail Stop 2736, Washington, D.C. 20549, or deliver it to Room 1120 at that address. Also, send a copy to the SEC Office of the General Counsel, Mail Stop 9612, or deliver it to Room 1120 at the Station Place address. In the interim, if you have any questions, please call me at (202) 551-7201, or contact me at sifordm@sec.gov. At any time you may request the status of your request by calling (202) 551-7900 or sending an e-mail to foiapa@sec.gov. Sincerely,

Mark P. Siford FOIA/Privacy Act Attorney Advisor