Comment Text:
Memo from Aaron Brodsky
CFTC Staff: Rick Shilts, Riva Adriance, Nancy Markowitz, Nadia Zakir, and Aaron Brodsky.
External Attendees: Pat Hamilton and Joe Wright.
On June 16, 2011, Commission staff participated in a conference call with representatives from ICAP Energy LLC to discuss EFS transactions.
During the call, ICAP and staff discussed the treatment of futures versus swaps and the factors that market participants typically consider when selecting a clearinghouse. ICAP and staff also discussed the role of EFS transactions in the current and future marketplace.
ICAP also expressed concern over certain aspects of the proposed 85% minimum centralized market trading requirement under Core Principle 9.
