Comment Text:
Dear Secretary Stawick:
On behalf of the Working Group of Commercial Energy Firms (the “Working Group”), Hunton & Williams LLP submits the following in response to the request for public comment set forth in the Notice of Proposed Rulemaking issued by the Commodity Futures Trading Commission (“CFTC” or “Commission”) and published in the Federal Register on December 7, 2010, proposing to implement real-time reporting requirements for counterparties to swap transactions, pursuant to new Section 2(a)(13) of the Commodity Exchange Act (“CEA”), as established by Section 727 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”).
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. Members of the Working Group are energy producers, marketers and utilities. The Working Group considers and responds to requests for public comment regarding regulatory and legislative developments with respect to the trading of energy commodities, including derivatives and other contracts that reference energy commodities.
Respectfully submitted,
R. Michael Sweeney, Jr.
Mark W. Menezes
David T. McIndoe
Counsel for the Working Group of Commercial Energy Firms
