Comment Text:
On behalf of the Working Group of Commercial Energy Firms (the “Working Group”), Hunton & Williams LLP hereby submits these comments in response to the request for public comment set forth in the Commodity Futures Trading Commission’s (the “CFTC” or “Commission”) Notice of Proposed Rulemaking, Core Principles and Other Requirements for Swap Execution Facilities, published in the Federal Register on January 7, 2011, which provides new regulations for the registration and operation of Swap Execution Facilities pursuant to new Sections 2(h)(8) and 5h of the Commodity Exchange Act, as established by Sections 723(a)(3) and 733, respectively, of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
The Working Group is a diverse group of commercial firms in the energy industry whose primary business activity is the physical delivery of one or more energy commodities to others, including industrial, commercial, and residential consumers. Members of the Working Group are energy producers, marketers, and utilities. The Working Group considers and responds to requests for public comment regarding regulatory and legislative developments with respect to the trading of energy commodities, including derivatives and other contracts that reference energy commodities.
The Working Group appreciates the opportunity to provide these comments. If you have any questions, please contact Michael Sweeney, Mark Menezes, or David McIndoe.
Respectfully submitted,
Meghan R. Gruebner
