Comment Text:
Attached please find comments on the Commission Staff's Draft Technical Specifications for Certain Swap Data Elements, along with several recommendation for regulatory prioritization with respect to proposing amendments to the Initial Swap Reporting Rules, and requests for regulatory relief for unregistered swap counterparties.
Respectfully submitted by:
Patricia Dondanville, Reed Smith LLP, on behalf of:
National Rural Electric Cooperative Association
American Public Power Association
