Agricultural Swaps Regulation - Comment Letter - Federal Energy Regulatory Commission - April 4, 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 4, 2011

From the comment letter:

"We have previously submitted comments on other proposed Dodd-Frank implementing rules in which we explained that, depending on how broadly the term "swap" is construed, CFTC regulation of swaps could lead to inconsistent regulation of participants and transactions subject to FERC jurisdiction, and in particular the organized electricity markets.4 For example, we noted that forward capacity sales in organized markets (i.e., regional transmission organizations and independent system operators) could be subject to regulation as "swaps," depending on how that term is defined...Under the proposed rule, these and other such arrangements could be subjected to potentially conflicting regulation by the CFTC and FERC.


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