External Meetings: Meeting w/ Private Equity Growth Capital Council

PEGCC discussed its February 10, 2014 comment letter  on Aggregation of Positions, including recommendations for: a notice filing process for an aggregation exemption, including the frequency and timing of such notices; and fund (owner) certification in lieu of board member certification. Topics also discussed were:  the utility of conditioning aggregation relief on consolidation not being required under GAAP; a recommendation that appropriate sanctions (e.g., for manipulation or disruptive trading) be imposed, but that a penalty box disqualification from aggregation relief was not practicable; and a request for clarification of aggregation requirements regarding contracts subject to exchange limits, but not subject to federal limits.
Aggregation Policy for Position Limits

Position Limits for Derivatives

CFTC Staff
Vincent A. McGonagle, Riva Adriance, Christa Lachenmayr,  Lee Ann Duffy, Scott Mixon, Stephen Sherrod
Steve Judge (PEGCC), Jason Mulvihill (PEGCC), Ken Raisler (Sullivan & Cromwell), Catherine Ziobro (Carlyle), Barrett Karr (Carlyle), David Reintjes (TPG), Travers Garvin (KKR), De'Ana Dow (Capitol Counsel), Omar Rehman (Blackstone), Ryne Miller (Sullivan & Cromwell)
Private Equity Growth Capital Council (PEGCC)