The external attendees discussed industry practices for municipal issuers that transact in swaps with respect to the following: (1) conflicts of interest (2)  policies and procedures for selecting a financial advisor; (3) independence standards; and (4) request for proposal processes.

Representatives for CFA further discussed the views expressed in its August 29, 2011 comment letter to the SEC on Business Conduct Standards with Counterparties.

The external attendees discussed industry practices for municipal issuers that transact in swaps with respect to the following: (1) conflicts of interest (2)  policies and procedures for selecting a financial advisor; (3) independence standards; (4) prohibitions on political contributions from dealers, and (5) request for proposal processes.

Representatives from BP companies asked for clarification about market risk and credit risk calculations under proposed capital rules for nonbank swap dealers.  CFTC staff responses included providing copy of Federal Reserve guidance at
http://fraser.stlouisfed.org/publications/frb/page/31359/4294/download/31359.pdf
at pages 959-960.

Participants discussed the treatment of managed assets under the provision in the definition of Eligible Contract Participant for commodity pools, including how the concept of commodity pool operator would be defined and applied.

CFTC staff received an email which forwarded CFA-AFR's comment letter to the SEC on Business Conduct Standards with Counterparties.

Participants discussed the general scope of the definition of swap dealer and how activities on swap execution facilities or similar platforms would be treated in the definition.

Representatives for ABC and CIEBA further discussed their views expressed in their August 29, 2011 comment letter to the SEC on Business Conduct Standards with Counterparties.

CFTC staff received an email which forwarded BlackRock's comment letter to the SEC on Business Conduct Standards with Counterparties.

Participants discussed the public interest waiver process provided for in Section 722(f) of the Dodd-Frank Act, and in particular as it applies to transactions between entities described in section 201(f) of the Federal Power Act (CEA section 4(c)(6)(C)).  Participants also discussed categories of transactions entered into by not-for-profit electric utilities, including full requirements contracts, capacity contracts, etc.