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External Meetings: Meeting with WSPP

When:
10/18/2012 3:00 PM
Rulemaking(s):
XXI. Joint Rules w/ SEC

CFTC Staff:
Terry Arbit

David Aron

Herminio Castro

Lee Ann Duffy

Julian Hammar

Kenneth McCracken

Gail Scott

Somi Seong

Jason Shafer
Visitor(s):
Arnold Podgorsky, Wright & Talisman PC

Patrick Morand, Wright & Talisman PC
Organization(s):
WSPP, Inc. (WSPP)

Wright & Talisman, PC
  • Participants discussed the interpretation in the product definitions concerning oral bookouts and the Brent Interpretation safe harbor for forward contracts.  WSPP representatives indicated that WSPP members generally would be in compliance with the interpretation’s requirement that oral bookouts be followed within a commercially reasonable timeframe by a confirmation in some type of written or electronic form.  WSPP raised a specific question about whether an electronic recording of a bookout would satisfy this requirement.  In addition, WSPP representatives  mentioned that members engage in volume bookouts, where multiple bookouts are documented in one transaction, rather than having to document each bookout separately, and inquired whether such volume bookouts would fall within the Brent Interpretation Safe Harbor.  Finally, existing language in the WSPP Agreement defining a bookout was discussed.

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