Comment Text:
Attached please find the comments of the Coalition of Physical Energy Companies (COPE) to the Reopening and Extension of Comment Periods for Rulemakings Implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act.
In addition to being global comments on the rulemaking process, the attached comments refer specifically to the following Commission-proposed rulemakings:
Real-Time Public Reporting of Swap Transaction Data (RIN No. 3038-AD08)
Swap Data Recordkeeping and Reporting Requirements (RIN No. 3038-AD19)
Further Definition of "Swap Dealer," "Security-Based Swap Dealer," "Major Swap Participant," "Major
Security-Based Swap Participant" and "Eligible Contract Participant" (RIN No. 3038-AD06)
Position Limits for Derivatives (RIN Nos. 3038-AD15 and 3038-AD16)
End-User Exception to Mandatory Clearing of Swaps (RIN No. AD-10)
Swap Trading Relationship Documentation Requirements for Swap Dealers and Major Swap Participants (RIN No. 3038-AC96)
Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties (RIN No. 3038-AD25)