Meeting Date:
Wednesday, June 22, 2011
CFTC Staff:
Terry Arbit
David Aron
Mark Fajfar
Julian Hammar
Steve Kane
Organization(s):
BG Americas & Global LNG (BG Americas)
Alpine Group
Hunton & Williams
External Attendees:
David Keene (BG Americas)
Matt Schatzman (BG Americas)
Jason Schendle (Alpine Group)
Michael Sweeney (Hunton & Williams)
Lisa Yoho (BG Americas)
Additional Information:
Participants discussed issues related to the swap dealer and major swap participant definitions. In particular BG Americas takes the view that the swap dealer definition is too broad, and that it would be helpful if the Commissions specified what activities do not constitute swap dealing. For the de minimis exemption, BG Americas recommended setting a higher notional amount at first, that could modified in light of data received about the markets. BG Americas also expressed concern with footnote 128 of the proposing release (in connection with the major swap participant definition), which it believes too broadly describes what does not constitute hedging or mitigating commercial risk. Participants also discussed the forward contract exclusion from the swap definition.
