Mr. Young urged that the Commission clarify in the position limits rulemaking that amounts of a commodity subject to long-term supply contracts could be considered part of the deliverable supply of that commodity for purposes of calculating the spot month position limit if commercial practice demonstrated that such amounts were in fact available for delivery in the spot month.

Meeting to discuss Customer Clearing Documentation and Timing of Acceptance for Clearing.

See attached letter signed by Senate Banking Committee Chairman Johnson and House Financial Services Ranking Member Barney Frank.

The meeting discussed issues raised in FTN Financial's comment letters dated Feb.

Representatives for AFR called CFTC staff to discuss the views expressed in AFR’s Feb. 22 commenter letter to the CFTC and Aug. 29 comment letter to the SEC and CFTC.  The AFR representative expressed his view that the Business Conduct Standards under the CFTC and SEC’s respective jurisdictions regulate different types of markets that may have different types of market participants, including certain Special Entities. The AFR representative expressed his view that those differences may justify the CFTC adopting Business Conduct Standards rules that are different from the SEC.

Representatives for CFA, AFR, and Better Markets further discussed the views expressed in their February 22 letters the the CFTC and August 29th letters to the SEC and CFTC.  The August 29th letters are available on the Commission's website in connection with the external attendees' September 16, 2011 meeting with CFTC staff.

The phone call discussed the attached comments and suggested language submitted by NRU CFC, which include (i) a suggested blanket exception from the definition of "swap" that would cover NRU CFC's activities; (ii) two alternative suggestions for the commercial end user exemption from the clearing requirement; and (iii) suggested options to define a de minimis amount of swap dealing that are intended to exclude cooperatives from the definition of swap dealer.

Participants discussed proposed CFTC regulations related to the protection of cleared swaps customer contracts and collateral.

Participants discussed proposed CFTC regulations related to the protection of cleared swaps customer contracts and collateral.

Discussion of the ability and cost of complying with proposed oral recordkeeping requirements in proposed amended Regulation 1.35(a) and proposed Regulation 23.202.