Comment Text:
On behalf of the Working Group of Commercial Energy Firms, Hunton & Williams LLP submits the following in response to the request for public comment set forth in the Joint Notice of Proposed Rulemaking, Further Definition of “Swap Dealer,” “Security-Based Swap Dealer,” “Major Swap Participant,” “Major Security-Based Swap Participant” and “Eligible Contract Participant” issued by the Commodity Futures Trading Commission and the Securities and Exchange Commission and published in the Federal Register on December 21, 2010, proposing to further define the term “Swap Dealer.”
The Working Group appreciates the opportunity to submit these comments and looks forward to working with the Commissions to further define the term "Swap Dealer." If you have any questions please contact me.
Respectfully Submitted,
Mark W. Menezes, Partner
Hunton & Williams LLP