Participants discussed extraterritoriality under DFA and the implementation timeline relative to the European Union.

Conference call on topics relating to the Regulation 1.25/30.7 rulemaking including MMMFs, asset-based and issuer-based concentration limits, counterparty concentration limits, in-house transactions and repurchase agreements with affiliates.

Conference call with FIA to discuss Regulation 1.25, with particular focus on in-house transactions. See attachments.

On July 11, 2011, CFTC staff participated via teleconference in a meeting with members of the WMBAA.  WMBAA shared its views on the rulemaking for Real-time Public Reporting. 
 

The meeting was to follow up on questions raised at a meeting with ISDA on March 31, 2011, and to hear ISDA’s reactions to the Joint Staff Roundtable on the Swap Dealer and Major Swap Participant (MSP) Definitions on June 16, 2011.  During the meeting, ISDA expressed the following views:

External participants, both in person and by phone, raised questions about treatment of inter-affilate transactions with respect to CFTC proposed rulemaking for margin requirements.

Participants discussed the applicability of the Dodd-Frank Act to international organizations such as the World Bank.

On June 29, 2011, Commission staff had a conference call with BP to discuss real-time reporting issues.
 
BP tends to operate on an end of day basis, so they currently run a number of processes overnight.  They do not see a risk management or control benefit with reporting faster than end of day.  Currently BP cannot separate cleared swaps from uncleared swaps, as their systems cannot do that.  Instead, they aggregate globally throughout BP to look at financials and physicals.
 

This brief discussion concerned the ECP definition:  the scope of the issues raised in comments about the application of the swaps policy statement to the ECP definition, and whether persons could gain ECP status by being advised with respect to swaps by an introducing broker or commodity trading adviser.

Representatives of UBS summarized points in attached document.