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Comment for Proposed Rule 75 FR 67657

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  • From: Ex Parte Communication
    Organization(s):
    American Petroleum Institute.
    National Petrochemical and Refiners Association.

    Comment No: 31668
    Date: 3/10/2011

    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

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