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Ex Parte Meeting for Proposed Rule 77 FR 48207

  • Title:
    Meeting with WSPP

    Ex Parte No: 743
    Date: 10/18/2012

    Meeting Date:

    Thursday, October 18, 2012

    CFTC Staff:

    Terry Arbit

    David Aron

    Herminio Castro

    Lee Ann Duffy

    Julian Hammar

    Kenneth McCracken

    Gail Scott

    Somi Seong

    Jason Shafer


    WSPP, Inc. (WSPP)

    Wright & Talisman, PC

    External Attendees:

    Arnold Podgorsky, Wright & Talisman PC

    Patrick Morand, Wright & Talisman PC

    Additional Information:

    Participants discussed the interpretation in the product definitions concerning oral bookouts and the Brent Interpretation safe harbor for forward contracts.  WSPP representatives indicated that WSPP members generally would be in compliance with the interpretation’s requirement that oral bookouts be followed within a commercially reasonable timeframe by a confirmation in some type of written or electronic form.  WSPP raised a specific question about whether an electronic recording of a bookout would satisfy this requirement.  In addition, WSPP representatives  mentioned that members engage in volume bookouts, where multiple bookouts are documented in one transaction, rather than having to document each bookout separately, and inquired whether such volume bookouts would fall within the Brent Interpretation Safe Harbor.  Finally, existing language in the WSPP Agreement defining a bookout was discussed.