The Working Group of Commercial Energy Firms (WGCEF) expressed the following views on the proposed definition of “swap dealer”: 
(1) The CFTC should finalize a narrow definition that would capture relatively few entities as swap dealers, and then gradually broaden the rule as more information about swap dealers’ activities becomes available.  If the CFTC were to start with a relatively broad rule it would be difficult to narrow its application in the future.

Telephone discussion regarding 1.25 treatment of CDs. See attached.

Discussion of LE implementation issues.

Discussion of LE implementation issues.

Discussion of LE implementation issues.

Discussion of 2020 position limits proposal.

Discussion of proposed rule on post-trade name give-up.

Discussed HSBC's submitted comments to the Volcker Rule.

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