Discussion of various issues related to CFTC's proposed Volcker Rule. Discussion of how commodity pools should be treated under the Volcker Rule. Discussion of various alternatives and approaches to the proposed Volcker Rule.
Discussion of the CFTC's proposed Volcker Rule. Discussion of market-making and hedging permitted activities. Discussion of metrics, compliance requirements, and various issues related to commodity pools.
Participants discussed: (i) implementation phase-in; (ii) extraterritoriality and cross border coordination; (iii) SEF and block rules issues; (iv) straight-through processing; (v) documentation; (vi) segregation of collateral (LSOC); and (vii) how contingent SEFs must be included in the de minimis exception calculation for determining whether an entity must register as a swap dealer.
External Meetings: Meeting with American Public Gas Association
Discussion of Margin Treatment of Natural Gas Municipal Prepayment Transactions. Diagram attached. CFTC team was advised a comment letter will follow separately.