Comment Text:
Sutherland Asbill & Brennan LLP submits the attached comment letter on behalf of The Commercial Energy Working Group in response to the Commodity Futures Trading Commission’s Request for Comment on Application of Commission Regulations to Swaps Between Non-U.S. Swap Dealers and Non-U.S. Counterparties Involving Personnel or Agents of the Non-U.S. Swap Dealers Located in the United States.