Comment Text:
On behalf of The Commercial Energy Working Group, Sutherland Asbill & Brennan LLP hereby submits these comments in support of and to further expound upon the August 23, 2012 comment letter submitted by ConocoPhillips in response to the proposed interpretive guidance regarding the treatment of forwards with embedded volumetric optionality by the Commodity Futures Trading Commission in its final rule further defining the term “swap." The Working Group appreciates the opportunity to provide the comments set forth herein and respectfully requests the Commission’s consideration of such comments.
Respectfully submitted,
David T. McIndoe
