The external attendees further discussed the views expressed in the February 18 comment letter signed by eleven public pension plans.

The external attendees further discussed their views on the proposed External Business Conduct Standards rules expressed in the SIFMA/ISDA February 17 comment letter.

The discussion centered around how the class limits in the proposed position limit rule would impact the representatives’ business.  The Swap Execution Facility (SEF) rulemaking was also discussed, including execution requirements and whether certain transactions would be classified as swaps or futures.

The group discussed the proposed position limits, with a focus on timing of implementation and account aggregation provisions.

Participants discussed concerns with the proposed rules relating to bona fide hedges.

Participants discussed proposed rules for business conduct standards.

In advance of a comment letter they plan to send regarding the CFTC's proposed margin requirements, representatives of the Committee on the Investment of Employee Benefits and American Benefits Council met with CFTC staff to express the view that pension plans should receive the same treatment provided to commercial end-users or to lower risk financial end-users in the proposed CFTC rule.  Alternatively, the Commission should consider requiring two-way margin between swap dealers and pension plans.