Comment Text:
Telephone Call from Ken Raisler of Sullivan & Cromwell
Friday, February 18, 2011
Memo from
Kneller, Theodore
CFTC Staff :
Phyllis Cela
Ted Kneller
External Attendees :
Ken Raisler (Sullivan)
David Passey (Sullivan)
Anthony Greco (Sullivan)
Additional Information :
On February 18, 2011, Ken Raisler, David Passey, and Anthony Greco of Sullivan & Cromwell LLP called on behalf of the Canada Pension Plan Investment Board and spoke to Phyllis Cela and Ted Kneller of the CFTC.
Mr. Raisler and his colleagues stated that (1) in their view the definition of Special Entity may capture foreign employee benefit plans, and (2) the CFTC’s interpretation of the employee benefit plan prong of the Special Entity definition should be limited to U.S. employee benefit plans.
