From:
Lillian A Forero
Organization(s):
Sutherland Asbill & Brennan LLP, on behalf of The Commercial Energy Working Group (the “Working Group”) and the Commodity Markets Council (“CMC,” together with the Working Group, the “Commercial Alliance”).
Comment Text:
On behalf of The Commercial Energy Working Group (the “Working Group”) and the Commodity Markets Council (“CMC,” together with the Working Group, the “Commercial Alliance”), Sutherland Asbill & Brennan LLP hereby submits these comments in response to the Commodity Futures Trading Commission’s (the “CFTC”) and Securities and Exchange Commission’s (the “SEC,” and together with the CFTC, the “Commissions”) Proposed Interpretation, Forward Contracts with Embedded Volumetric Optionality (the “Proposed Interpretation”).
