Participants discusse the end user clearing exception for small financial insitutions.

Discussion surrounded key issues affecting ICE's conversion to futures.

Discussion of the August 2011 comment letter by the Working Group of Commercial Energy Firms concerning the potential cost of proposed amended recordkeeping requirements to Regulation 1.35(a).

Participants discussed regulatory services for SEFs.

- Interest Rates Swaps Dealer providing perspective of a new market participant. Recommended that in light of new market entrants who will be self-managing risk, Commission should give consideration to a balance between transparency and liquidity that does not disadvantage smaller firms acting as liquidity providers.

Parity Energy

Managed Funds Association discussed the following aspects of the FNPRM:


 


- Recommended that swap categories be estabished based on product type for each asset class, e.g.; also recommended separate categories for CDS for indexes, options, and tranches;


 


- Opposed use of 3-month data set in calculating minimum block sizes and recommended conceptual test to check minimum block sizes against current market conditions


 

Participants discussed the position limits reporting requirements.

Participants discussed NPEC exemption request under 4(c) 6 of the Commodity Exchange Act for Electric Operations-Related Transactions between NFP Electric Entities; the $25 million Special Entities sub-threshold in the entities definition interim final rule and the definition of "swap," and the regulatory uncertainties that face a nonfinancial end user as it is about to enter into a nonfinancial commodity transaction.

Discussion of the CFTC's proposed Volcker Rule.  Discussion of the hedging and market-making exemptions.


 


Discussion of the CFTC's public roundtable.