Comment Text:
On behalf of The Commercial Energy Working Group, Sutherland Asbill & Brennan LLP respectfully submits the attached letter in response to the request for public comment set forth in the Commodity Futures Trading Commission’s Proposed Rule; Interpretations, Cross-Border Application of the Registration Thresholds and External Business Conduct Standards Applicable to Swap Dealers and Major Swap Participants (RIN 3038-AE54).
