Meeting Date:
Monday, September 22, 2014
CFTC Staff:
Vincent A. McGonagle, Riva Adriance, Christa Lachenmayr, Lee Ann Duffy, Scott Mixon, Stephen Sherrod
Organization(s):
Private Equity Growth Capital Council (PEGCC)
External Attendees:
Steve Judge (PEGCC), Jason Mulvihill (PEGCC), Ken Raisler (Sullivan & Cromwell), Catherine Ziobro (Carlyle), Barrett Karr (Carlyle), David Reintjes (TPG), Travers Garvin (KKR), De'Ana Dow (Capitol Counsel), Omar Rehman (Blackstone), Ryne Miller (Sullivan & Cromwell)
Additional Information:
PEGCC discussed its February 10, 2014 comment letter on Aggregation of Positions, including recommendations for: a notice filing process for an aggregation exemption, including the frequency and timing of such notices; and fund (owner) certification in lieu of board member certification. Topics also discussed were: the utility of conditioning aggregation relief on consolidation not being required under GAAP; a recommendation that appropriate sanctions (e.g., for manipulation or disruptive trading) be imposed, but that a penalty box disqualification from aggregation relief was not practicable; and a request for clarification of aggregation requirements regarding contracts subject to exchange limits, but not subject to federal limits.
