Meeting Date:
Tuesday, May 17, 2011
CFTC Staff:
Phyllis Cela
Peter Sanchez
Katie Driscoll
Ted Kneller
Organization(s):
Skadden, Arps, Slate, Meagher & Flom LLP (Skadden)
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
External Attendees:
Mark Young (Skadden)
Maureen Donley (Skadden)
Rachel Kaplan Reicher (Skadden)
Additional Information:
The external attendees expressed concerns about the proposed External Business Conduct Standards rules and further discussed the views expressed in February 22 comment letter from ABC/CIEBA and the May 3 comment letter from ABC.
The external attendees raised issues regarding the effective date of statutory provisions under §4s(h) of the Commodity Exchange Act. The external attendees expressed their view that there would be a problem if the provision was effective in July 2011, and Commission guidance would be appropriate to avoid disruptions to ERISA pension plan’s access to the swaps markets.
