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Comment for General CFTC General Dodd-Frank Submissions

  • From: Sweeney R.Michael
    Organization(s):

    Comment No: 46519
    Date: 9/20/2010

    Comment Text:

    Via Electronic Delivery

    Dear Secretary Stawick:

    On behalf of the Working Group of Commercial Energy Firms (the “Working Group”), Hunton & Williams LLP hereby submits this letter providing pre-rulemaking, preliminary comments addressing the definitions of “Futures Commission Merchant,” “Floor Broker,” and “Floor Trader,” as adopted in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act").

    The Working Group is a diverse group of commercial firms in the energy industry whose primary business activity is the physical delivery of one or more energy commodities to others, including industrial, commercial and residential consumers. Members of the Working Group include energy producers, marketers and utilities. The Working Group considers and responds to requests for public comment regarding legislative and regulatory developments with respect to the trading of energy commodities, including derivatives and other contracts that reference energy commodities.

    The Working Group appreciates the opportunity to submit these comments and looks forward to working with the Commodity Futures Trading Commission to further define and clarify these definitions as part of the formal rulemaking process implementing Title VII of the Act.

    If you have any questions, or if the Working Group may be of further assistance, please do not hesitate to contact me directly at the number listed below.

    -- Respectfully submitted,

    R. Michael Sweeney, Jr.

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    __________________________________________

    R. Michael Sweeney, Jr.

    Hunton & Williams LLP

    1900 K Street, N.W.

    Suite 1200

    Washington, D.C.

    (202) 955-1944

    rsweeney@hunton.com

    ___________________________________________

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