Comment Text:
Attached please find comments on the topic of the third panel of the April 3, 2014 Public Roundtable: the special entity sub-threshold to the de minimis exception to the swap dealer definition in CFTC Rule 1.3(ggg)(iv).
Respectfully submitted by:
Patricia Dondanville, Reed Smith LLP, on behalf of:
American Public Power Association
Large Public Power Council
Bonneville Power Administration
