External Meetings: Meeting with Skadden

When:

5/17/2011 9:30 AM

Rulemaking(s):

III. Business Conduct Standards w/ Counterparties

CFTC Staff:

Phyllis Cela

Peter Sanchez

Katie Driscoll

Ted Kneller

Visitor(s):

Mark Young (Skadden)

Maureen Donley (Skadden)

Rachel Kaplan Reicher (Skadden)

Organization(s):

Skadden, Arps, Slate, Meagher & Flom LLP (Skadden)

American Benefits Council (ABC)

Committee on Investment of Employee Benefit Assets (CIEBA)

The external attendees expressed concerns about the proposed External Business Conduct Standards rules and further discussed the views expressed in February 22 comment letter from ABC/CIEBA and the May 3 comment letter from ABC. ~ ~The external attendees raised issues regarding the effective date of statutory provisions under §4s(h) of the Commodity Exchange Act. The external attendees expressed their view that there would be a problem if the provision was effective in July 2011, and Commission guidance would be appropriate to avoid disruptions to ERISA pension plan’s access to the swaps markets.