CFTC staff met with SIFMA representatives to discuss issues that were submitted in SIFMA's publicly available comment letters relating to the implementation of the Volcker Rule.

The meeting discussed two subsidiaries that act as centralized hedging centers with respect to Kraft Foods’ operations outside of North America – Kraft Foods Finance Europe (KFFE) acts as in-house treasury and centralizes global cash management, and Taloca GmbH is a centralized procurement unit for globally managed commodities.  KFFE uses currency swaps, forwards and options to manage foreign exchange risks.  Taloca uses commodity futures, forwards and options to manage price and supply risks.  KFFE and Taloca each enter into swaps with third-party dealers as necessary to

Getco discussed views on the Dodd-Frank Act generally, and provided comments on proposed conflicts of interest rules for SEFs specifically.

Meeting to discuss the swap definition, the loan syndication market, loan credit default swaps and the loan credit default swap index.

Discussion concerning collateral and margin requirements under Dodd Frank

Documentation associated with the swap transactions (master agreement, confirmation, credit support agreement, etc.)

NARUC’s primary comment is that the regulations implemented under the Dodd-Frank Act and in particular margin requirements for swaps should not inappropriately increase costs for regulated utilities (which are end users of swaps), since the utilities’ costs would be passed on to consumers.  Also, posting of margin for swaps by utilities would draw capital away from other uses that would improve service to consumers.  The regulations should also avoid redundancy with other regulations to which the utilities are subject.

Mr.