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External Meetings: Definitions and End User Phone Call with NRU CFC

10/5/2011 12:00 PM
II. Definitions

XI. End-user Exception

XXI. Joint Rules w/ SEC

CFTC Staff:
Mark Fajfar
Richard E. Larochelle (NRU CFC)

Ed Barron (Russell & Barron)
National Rural Utilities Cooperative Finance Corporation (NRU CFC)

Russell & Barron
  • The phone call discussed the attached comments and suggested language submitted by NRU CFC, which include (i) a suggested blanket exception from the definition of "swap" that would cover NRU CFC's activities; (ii) two alternative suggestions for the commercial end user exemption from the clearing requirement; and (iii) suggested options to define a de minimis amount of swap dealing that are intended to exclude cooperatives from the definition of swap dealer.