Meeting Date:
Friday, September 16, 2011
CFTC Staff:
David E. Aron
Organization(s):
Willkie Farr & Gallagher LLP
External Attendees:
Rita M. Molesworth (Willkie Farr & Gallagher LLP)
Additional Information:
Discussion of various implications of the proposed "look through" in the definition of Eligible Contract Participant (ECP) in CEA section 1a(18), and whether ECP status could apply under prong (v) of the definition if persons cannot satisfy prong (iv) thereof. Also discussion of various possible interpretations of the “subject to regulation” language in (iv)(II).
