Comment Text:
On behalf of the Working Group of Commercial Energy Firms and the Commodity Markets Council (collectively, the “Commercial Alliance”), 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”) Reopening and Extension of Comment Periods for Rulemakings Implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, published in the Federal Register on May 4, 2011, which reopens and extends until June 3, 2011, the comment period of many of the CFTC’s proposed rulemakings.
Specifically, the Commercial Alliance submits these comments to express its concerns with the virtually identical language set forth in footnote 128 and footnote 23 (collectively, the “Footnotes”) of the Definitions Proposed Rule and the End-User Exception Proposed Rule, respectively (collectively, the “Proposals”).
The Commercial Alliance appreciates the opportunity to comment and submits for the Commission’s consideration comments and recommendations it believes will assist the Commission in developing final rules that will preserve the integrity of the swap markets and serve the best interests of market participants.
If you have any questions, please contact me.
Respectfully submitted,
Matthew C. Thomas
Government Affairs Assistant
Hunton & Williams LLP
