In advance of a more detailed comment letter they plan to file in response to proposed margin requirements, representatives of the ASF summarized discussion points in the attached document.

The meeting covered various issues related to the ECP definition.  Wells Fargo expressed a concern that middle market borrowers would not be permitted to hedge in certain cases and that Wells Fargo might, as a result, scale back its lending to those customers if Wells Fargo cannot enter appropriate hedges in connection with its loans.  The scenarios discussed in the meeting all related to who can be an ECP in connection with interest rate swaps hedging loans in various circumstance.  Wells Fargo advanced the following solutions:  (1) joint and several liability among en

Spring Trading met with Staff to discuss SEF registration and demonstrate its platform.

The participants discussed various issues related to large swaps trader reporting, including the mechanics and implementation of reporting.

The participants discussed various aspects of the large swaps trader reporting rules, including reporting mechanics and data fields.

The participants discussed various issues related to large swaps trader reporting, including frequency of reporting and reporting mechanics.

The meeting took place via conference call.  The participants discussed aspects of the proposed large swaps trader reporting system and relation to position limits.

Ford representatives summarized the points made in the comment letter filed by the firm in response to the Commission's proposed margin rules.

Discussion of LEI implementation issues

Approaches to using FIX, FpML, and DOI to lessen the complexity of implementing a product registry for OTC derivatives