Agricultural Swaps Regulation - Comment Letter - Commodity Options and Agricultural Swaps Working Group - April 11, 2011

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Dodd-Frank Timeline, Commodity Options and Agricultural Swaps
Final Rule-Swaps Effective Date - Swaps Effective Date-Options
August 10, 2011 December 31, 2011 June 26, 2012

Commodity Options and Agricultural Swaps
April 11, 2011

The comment letter was submitted by the law firm Cadwallader, Wickersham & Taft LLC on behalf of the the Commodity Options and Agricultural Swaps Working Group, which consists of the following entities:

  • Barclays Capital,
  • Citigroup,
  • Credit Suisse Securities (USA),
  • JPMorgan Chase & Co.,
  • Morgan Stanley, and
  • Wells Fargo & Company.

The Working Group requests that the commission "reconsider its proposal to regulate options on physical commodities as swaps," and instead permit options on physical commodities to be traded "subject only to the conditions that the transaction:

  1. is intended to be physically settled upon exercise, and
  2. meets the requirements currently set forth in Commission Regulation 32.4 for trade options."

The letter suggests that, until its rules regarding the definition of the term "swap," its ruling on agricultural swaps should be deferred.


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