Mr.

The meeting discussed points made in FIA's comment letter on the aggregation rule proposal for position limits, including in light of the court decision on the position limits rule.  The meeting also discussed the treatment of certain transactions, such as basis swaps, under the bona fide hedging rules.

Participants discussed the CFTC’s interpretations in the product definitions final release regarding forwards with volumetric options and lease-like commercial transactions.  SCE and Southern expressed concern about the 7th factor in the forwards with volumetric optionality interpretation, specifically the requirement that volumetric optionality be due to physical factors outside of the control of the parties.  They asserted that contracting parties would not know at the point of execution of their contracts whether volumetric optionality would be due to physical factors, making

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  mention

FHLBank discussed their comment letter regarding the proposed cooperative exemption from mandatory clearing.

Discussed implementation issues related to methods to calculate capital charges for credit risk, including models, model approvals and standardized tables.

Discussed reporting issues and margin for uncleared swaps.

Discussion limited solely to content of previously filed comment letter.