External Meetings: Meeting with Skadden

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.