Comment Text:
The National Rural Electric Cooperative Association, the American Public Power Association, the Large Public Power Council and the Transmission Access Policy Study Group respectfully submit this comment on the joint final rule and interpretations issued by the CFTC and the SEC captioned Further Definition of “Swap,” “Security-Based Swap,” “Security-Based Swap Agreement”; Mixed Swaps; Security-Based Swap Agreement Recordkeeping.
Patricia Dondanville
Reed Smith LLP
