Comment Text:
On behalf of the Commercial Energy Working Group, Sutherland Asbill & Brennan LLP hereby submits this letter in response to the CFTC's December 17, 2012 Notice requesting public comment on its annual Form TO recordkeeping requirement provided in the interim final rule governing the trade option exemption.
If you have any questions, please contact the undersigned.
Respectfully submitted,
Meghan R. Gruebner, Associate, Sutherland Asbill & Brennan LLP
Counsel to the Commercial Energy Working Group
