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Ex Parte Meeting for Proposed Rule 75 FR 76139

  • Title:
    Conference Call with BP

    Ex Parte No: 306
    Date: 6/29/2011

    Meeting Date:

    Wednesday, June 29, 2011

    CFTC Staff:

    Jeff Steiner
    George Pullen
    Steve Kane
    Laurie Gussow
    Dan McKeever
    Carl Kennedy

    Organization(s):

    BP

    External Attendees:

    Vincent Johnson (BP)
    Alan Haywood (BP)
    Andy Milnes (BP)
    Mark Stultz (BP)
    Gregory Demoll (BP)
    Marc Cornelius (BP)

    Additional Information:

    On June 29, 2011, Commission staff had a conference call with BP to discuss real-time reporting issues.
     
    BP tends to operate on an end of day basis, so they currently run a number of processes overnight.  They do not see a risk management or control benefit with reporting faster than end of day.  Currently BP cannot separate cleared swaps from uncleared swaps, as their systems cannot do that.  Instead, they aggregate globally throughout BP to look at financials and physicals.
     
    BP suggested that the end of 2012 is a reasonable time for them to be able to comply with real-time reporting since they currently have a global system and would be required to build different systems. BP added that an end of 2012 timeframe would allow them time to budget the resources necessary for real-time reporting compliance (technology upgrades, etc.) since those items are budgeted on an annual basis, and BP would need to define and include them in their 2012 budget before the year began.

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