External Meetings: Meeting with representatives of ERISA plans

In advance of a comment letter they plan to send regarding the CFTC's proposed margin requirements, representatives of the Committee on the Investment of Employee Benefits and American Benefits Council met with CFTC staff to express the view that pension plans should receive the same treatment provided to commercial end-users or to lower risk financial end-users in the proposed CFTC rule.  Alternatively, the Commission should consider requiring two-way margin between swap dealers and pension plans.