Met to discuss rules regarding trade processing.

Met to discuss rules regarding margin requirements for uncleared swaps for swap dealers and major swap participants.

Mr. Berkovitz provided general information regrarding the status of various CFTC proposed rulemakings, particularly with respect to proposed rulemakings of interest to banks.  Mr.

Mr. Berkovitz provides a general overview of the CFTC's rulemakings to implement the Dodd-Frank legislation.  Questions following the presentation concerned the potential application of the swap dealer definition to energy firms, the timetable for implementation of rulemakings, the scope of the violations covered by the whistleblower provision, and margin requirements for uncleared swaps.

The meeting took place via conference call.  The participants discussed various issues related to position limits, including commodity indexes and recent trends in the derivatives markets.

The external attendees discussed their views on the proposed External Business Conduct Standards rules.  The external attendees memorialized their views in the June 3 comment letter from ABC/CIEBA.  The external attendees also discussed their views expressed in the February 22 comment letter from ABC/CIEBA, March 25 comment letter from Kent Mason, May 3 comment letter from ABC, and the May 19 comment letter from ABC/CIEBA.

See attached email.

The external attendees made some drafting suggestions related to their written comments on the proposed External Business Conduct Standards rules and further discussed the views expressed in the February 22 comment letter from ABC/CIEBA, March 25 comment letter from Kent Mason, May 3 comment letter from ABC, and the May 19 comment letter from ABC/CIEBA.
 

Participants discussed the meaning of the terms "narrow-based security index" and "issuers of securities in a narrow-based security index" as it relates to Title VII instruments referencing indexes of loans.

The meeting took place at the offices of the SEC in Washington, D.C.  CFTC staff joined by telephone conference. Attendees discussed matters related to the end-user exception to mandatory clearing including specific issues raised in a comment letter from Cravath, Swaine & Moore dated 2/4/11.  Better Markets argued for enlarging the universe of data collected regarding the ability to meet calls for collateral in the event of a credit trigger.