External Meetings: National Council of Farmer Coops

External Meetings: National Council of Farmer Coops

The Chairman met with the board of the NCFC to discuss Dodd-Frank rulemaking. Specifically, the Chairman discussed the forward exclusion contained in the proposed rules concerning product definitions and the proposed definition of swap dealer. During the question and answer session, the group discussed the structure of coop transactions with members and how the coops subsequently lay off risk to swap dealers or use futures to hedge the risks. In addition, they discussed how farmers and coops are seeking to hedge risks farther out than what's available in futures markets.

External Meetings: Meeting with ISDA

External Meetings: Meeting with ISDA

On April 21, 2011 representatives of the CFTC and the SEC met with representatives of the International Swaps and Derivatives Association (“ISDA”).  At the meeting ISDA’s representatives discussed ISDA’s April 14, 2011 white paper (copy attached) regarding product identifiers for standardized swaps and security-based swaps.  Additionally, ISDA representatives discussed how real-time data could be displayed to the public and the use of product identifiers for that purpose.

External Meetings: Definitions Meeting with MFX Solutions

External Meetings: Definitions Meeting with MFX Solutions

CFTC staff participated in a meeting with MFX Solutions, Inc. (“MFX”), a microfinance industry collaboration that supports microfinance lending in developing markets by supporting currency hedging in those markets. MFX expressed that, given the small total notional and average contract amounts, and the purpose of the swap activity they are engaged in, they should not be considered a “Swap Dealer” for the purposes of the rulemaking.

External Meetings: Meeting Regarding Comments on Proposed Risk Management Requirements for DCOs; Processing, Clearing and Transfer of Customer Positions; and Implementation and Sequencing of Final Rules

External Meetings: Meeting Regarding Comments on Proposed Risk Management Requirements for DCOs; Processing, Clearing and Transfer of Customer Positions; and Implementation and Sequencing of Final Rules

On April 15, 2011, at 1:00 p.m. EDT, Chairman Gensler and Commission staff participated in a meeting with representatives of Blue Mountain, Citadel, Delta, D.E. Shaw, DRW and Tudor. Topics discussed included implementation and sequencing of Dodd-Frank final rules, open access to derivatives clearing organizations, straight-through processing for cleared swaps, margin requirements for cleared swaps, segregation of collateral for cleared swap positions, and the process for mandatory clearing determinations. Industry representatives provided several documents (attached).