External Meetings: Call with Parity Energy

Parity Energy
XVIII. Real Time Reporting

Block Sizes for Large Notional Off-Facility Swaps

CFTC Staff
George Pullen

John Dunfee

Nhan Nguyen

Stephen Sherrod

John Paul Rothenberg

Gregory Kuserk

Esen Onur
Charles Reyl (Parity Energy)

Brad Flaster (Parity Energy)

Sara Lesch (Parity Energy)
Parity Energy discussed the following aspects of the FNPRM:


- Requested a separate swap category for swaps that are economically related to crude oil options because transactions in such options are typically larger in scale and fewer in number than those in fixed price energy instruments;


- Requested that the final rule to clarify that any natural gas swap with optionality be subject to the minimum block size proposed in Appendix F of the FNPRM for natural gas options rather than the minimum block size for natural gas swaps;


- Recommended setting a separate initial minimum block size for crude oil options at 1,000 contracts, consistent with CME’s minimum block size for Light Sweet Crude Oil options transactions.