Comment Text:
On behalf of the Working Group of Commercial Energy Firms (the “Working Group”), Hunton & Williams LLP hereby submits this letter to the Commodity Futures Trading Commission (the “CFTC” or “Commission”) to request clarification of certain aspects of the Commission’s Notice of Proposed Rulemaking regarding the definition of “swap dealer,” as required for promulgation pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. Specifically, the Working Group is commenting on the Commission’s proposal to permit non-financial entities to register as swap dealers, if appropriate, through a division of a legal entity, as opposed to registering an entire legal entity as a swap dealer.
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Respectfully Submitted,
Matthew C. Thomas
Government Affairs Assistant
Hunton & Williams LLP
