Comment Text:
On behalf of The Commercial Energy Working Group, Sutherland Asbill & Brennan LLP hereby submits these comments in response to the CFTC’s request for comment regarding the exclusion of utility operations-related swaps with utility special entities from the special entity de minimis threshold.
The Commercial Energy Working Group appreciates the opportunity to submit these comments and requests the Commission’s consideration of them.
Respectfully submitted,
Meghan R. Gruebner, Counsel to The Commercial Energy Working Group
