External Meetings: Meeting with Skadden

The external attendees made some drafting suggestions related to their written comments on the proposed External Business Conduct Standards rules and further discussed the views expressed in the February 22 comment letter from ABC/CIEBA, March 25 comment letter from Kent Mason, May 3 comment letter from ABC, and the May 19 comment letter from ABC/CIEBA. ~ ~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.~ ~The external attendees addressed the application of the final External Business Conduct Standards rules to transactions described in §4s(h)(7).