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External Meetings: Conference Call with Managed Funds Association

9/15/2011 3:30 PM
XXI. Joint Rules w/ SEC

CFTC Staff:
Terry Arbit

David Aron

Julian Hammar

Jason Shafer
Laura Harper (MFA)

Ken Raisler (Sullivan Cromwell)

Joanne Madero (Blackrock)

Sullivan Cromwell

  • 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.