Comment Text:
On behalf of the Working Group of Commercial Energy Firms, Hunton & Williams LLP hereby submits these comments in response to the request for public comment set forth in the Commodity Futures Trading Commission’s Notice of Proposed Rulemaking, End-User Exception to Mandatory Clearing of Swaps, published in the Federal Register on December 23, 2010, which proposes to provide “non-financial entities,” i.e., commercial firms, with an exception from the mandatory clearing requirements pursuant to new Section 2(h)(7) of the Commodity Exchange Act, as established by Section 723 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
The Working Group appreciates the opportunity to provide these comments. If you have any questions, please contact Michael Sweeney or Mark Menezes.
Respectfully submitted,
Meghan R. Gruebner
