Comment Text:
On behalf of the Working Group of Commercial Energy Firms (the “Working Group”), Hunton & Williams LLP hereby submits these supplemental comments on the definition of “swap dealer” in response to the request for public comment set forth in the Commodity Futures Trading Commission’s initial Notice of Proposed Rulemaking, Further Definition of ``Swap Dealer,'' ``Security-Based Swap Dealer,'' ``Major Swap Participant,'' ``Major Security-Based Swap Participant'' and ``Eligible Contract Participant'', published in the Federal Register on December 21, 2010.