Comment Text:
Dear Secretary Stawick:
On behalf of the Working Group of Commercial Energy Firms (the “Working Group”), Hunton & Williams LLP hereby re-submits the attached comments to the “Interim Final Rule for the Reporting of Pre-enactment Swap Transactions” issued by the Commodity Futures Trading Commission (“CFTC”) pursuant to Title VII, Section 729 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) and published in the Federal Register on October 14, 2010.
The Working Group is a diverse group of commercial firms in the energy industry whose primary business activity is the physical delivery of one or more energy commodities to others, including industrial, commercial and residential consumers. The Working Group (i) supports tailored regulation that brings transparency and stability to the energy Swap markets in the United States, and (ii) appreciates the balance the CFTC must strike between effective regulation and not hindering the Swap markets for energy commodities.
Due to technical difficulties, the Working Group's comments were not uploaded to the CFTC website upon their initial submission. As such, the Working Group is resubmitting their comments in both electronic and hard-copy format.
Again, the Working Group appreciates the CFTC’s efforts in issuing the Interim Final Rule, and welcomes the opportunity to submit comments in this proceeding.
If you have any questions, or if the Working Group can be of further assistance, please do not hesitate to contact me directly at (202) 955-1500.
Respectfully submitted,
R. Michael Sweeney, Jr.
Counsel for the Working Group of Commercial Energy Firms
