Meeting Date:
Wednesday, October 5, 2011
CFTC Staff:
Mark Fajfar
Organization(s):
National Rural Utilities Cooperative Finance Corporation (NRU CFC)
Russell & Barron
External Attendees:
Richard E. Larochelle (NRU CFC)
Ed Barron (Russell & Barron)
Additional Information:
The phone call discussed the attached comments and suggested language submitted by NRU CFC, which include (i) a suggested blanket exception from the definition of "swap" that would cover NRU CFC's activities; (ii) two alternative suggestions for the commercial end user exemption from the clearing requirement; and (iii) suggested options to define a de minimis amount of swap dealing that are intended to exclude cooperatives from the definition of swap dealer.
