Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - National Council of Farmer Cooperatives - August 8, 2011

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Adaptation of CFTC Regulations to Incorporate Swaps
August 8, 2011

From the comment letter:

"NCFC is concerned with this [Regulation 1.35] proposal because it would not only add swaps to the new recordkeeping requirements, but also would extend the new recordkeeping requirements to cash purchase and forward cash contracts entered into by any member of a designated contract market (DCM)...the proposed change to 1.35(a) would require those elevators to record, among other things, all oral communications that lead to execution of cash transactions with farmers.

"We do not believe that requiring this additional information to be recorded and maintained is necessary to achieve the stated goals in the cash commodity markets. Additionally, we do not believe the intent of the Dodd-Frank Act was to subject cash purchases and forward cash contracts to the additional new recordkeeping requirements proposed under regulation 1.35."


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