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External Meetings: Conference Call with Managed Funds Association
Rulemaking(s):
XXI. Joint Rules w/ SEC
CFTC Staff:
Terry Arbit
David Aron
Julian Hammar
Jason Shafer
Visitor(s):
Laura Harper (MFA)
Ken Raisler (Sullivan Cromwell)
Joanne Madero (Blackrock)
Organization(s):
MFA
Sullivan Cromwell
Blackrock
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Participants discussed the MFA's comment letter with respect to the Commission's guidance in the NPRM concerning forwards. MFA clarified its concern expressed in its comment letter with respect to the withdrawal of the Energy Exemption, and its request that the Commission confirm that market participants will be permitted to rely on "alternative delivery procedures" specified in the Exemption. MFA stated that by "alternative delivery procedures," it meant the provision of the Energy Exemption that permits certain bilateral netting and other similar agreements.