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Ex Parte Meeting for Proposed Rule 76 FR 29818

  • Title:
    Conference Call with Managed Funds Association

    Ex Parte No: 387
    Date: 9/15/2011

    Meeting Date:

    Thursday, September 15, 2011

    CFTC Staff:

    Terry Arbit

    David Aron

    Julian Hammar

    Jason Shafer



    Sullivan Cromwell


    External Attendees:

    Laura Harper (MFA)

    Ken Raisler (Sullivan Cromwell)

    Joanne Madero (Blackrock)

    Additional Information:

    Participants discussed the MFA's comment letter with respect to the Commission's guidance in the NPRM concerning forwards.  MFA clarified its concern expressed in its comment letter with respect to the withdrawal of the Energy Exemption, and its request that the Commission confirm that market participants will be permitted to rely on "alternative delivery procedures" specified in the Exemption.  MFA stated that by "alternative delivery procedures," it meant the provision of the Energy Exemption that permits certain bilateral netting and other similar agreements.

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