External Meetings: Telephone Call from Ken Raisler of Sullivan & Cromwell

On February 18, 2011, Ken Raisler, David Passey, and Anthony Greco of Sullivan & Cromwell LLP called on behalf of the Canada Pension Plan Investment Board and spoke to Phyllis Cela and Ted Kneller of the CFTC.  ~ ~Mr. Raisler and his colleagues stated that (1) in their view the definition of Special Entity may capture foreign employee benefit plans, and (2) the CFTC’s interpretation of the employee benefit plan prong of the Special Entity definition should be limited to U.S. employee benefit plans.