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External Meetings: Meeting with Skadden

5/17/2011 9:30 AM
III. Business Conduct Standards w/ Counterparties

CFTC Staff:
Phyllis Cela

Peter Sanchez

Katie Driscoll

Ted Kneller
Mark Young (Skadden)

Maureen Donley (Skadden)

Rachel Kaplan Reicher (Skadden)
Skadden, Arps, Slate, Meagher & Flom LLP (Skadden) 

American Benefits Council (ABC)

Committee on Investment of Employee Benefit Assets (CIEBA)
  • The external attendees expressed concerns about the proposed External Business Conduct Standards rules and further discussed the views expressed in February 22 comment letter from ABC/CIEBA and the May 3 comment letter from ABC. ~ ~The external attendees raised issues regarding the effective date of statutory provisions under §4s(h) of the Commodity Exchange Act.  The external attendees expressed their view that there would be a problem if the provision was effective in July 2011, and Commission guidance would be appropriate to avoid disruptions to ERISA pension plan’s access to the swaps markets.