Comment Text:
Meeting with American Petroleum Institute and National Petrochemical and Refiners Association
Thursday, March 10, 2011
Memo from
Higgins, Mark
CFTC Staff :
Chairman Gary Gensler, Tim Karpoff, Dan Berkovitz, Steven Seitz, Vince McGonagle, Robert Pease, Mark Higgins
External Attendees :
Daniel Waldman of Arnold & Porter on behalf of National Petrochemical and Refiners Association, Gregory Scott, National Petrochemical and Refiners Association, Tim Hogan, National Petrochemical and Refiners Association, Robert Long, Covington & Burling on behalf of American Petroleum Institute, Janice Raburn, American Petroleum Institute.
Additional Information :
At the meeting with the Chairman, API and NPRA presented the following topics for discussion:
Scope of Proposed Rule 180.1
Application of Manipulation Sanctions to Non-Manipulative Practices
Level of intent required for a violation of proposed Rule 2180.1 - Role of "attempts" in the application of proposed Rule 180.1
Exception for Good-faith Conduct and Mistakes
Limited application of proposed Rule 180.1 in the context of omissions
