UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

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

February 21, 2012

Mr. Michael Brozzetti Boundless LLC 3513 Bowman Street Philadelphia, PA 19129 Re: Freedom Request Request Request of Information Act (FOIA), 5 U.S.C. 552 No. 11-06336-FOIA No. 11-00114-APPS No. 11-00033-REMD

This is a final response to the remand of the FOIA request you filed on April 29, 2011. You sought the following records: 1. [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; and 2. A signed acknowledgment to the Code of Ethics for each Commission employee. You appealed an initial decision advising you that no responsive information could be located. Your appeal, however, only addressed the adequacy of the search for information responsive to No. 1. No objection was made to the finding of no responsive records for No. 2. The Commissions Office of the General Counsel remanded your request so that a more adequate search could be conducted based upon clarifying information you provided in your appeal. At this time, we have conducted another search and again determined that no responsive records exist.

Mr. Michael Brozzetti February 21, 2012 Page 2

11-00033-REMD

You have the right to appeal the adequacy of our search or finding of no responsive information, to our General Counsel under 5 U.S.C. 552(a)(6), 17 CFR 200.80(d)(5) and (6). 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 Office of FOIA Services 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. If you have any questions, please contact me by email at sifordm@sec.gov or by telephone at (202) 551-7201. If you cannot reach me please contact Mr. John J. Livornese by calling (202) 551-7900 or by sending an e-mail to foiapa@sec.gov. Sincerely,

Mark P. Siford Office of FOIA Services Attorney Advisor