External Meetings: Meeting with American Petroleum Institute and National Petrochemical and Refiners Association
At the meeting with the Chairman, API and NPRA presented the following topics for discussion:~Scope of Proposed Rule 180.1~Application of Manipulation Sanctions to Non-Manipulative Practices~Level of intent required for a violation of proposed Rule 2180.1 - Role of "attempts" in the application of proposed Rule 180.1~Exception for Good-faith Conduct and Mistakes~Limited application of proposed Rule 180.1 in the context of omissions
When
Rulemaking(s)
XXIII. Anti-Manipulation
CFTC Staff
Chairman Gary Gensler, Tim Karpoff, Dan Berkovitz, Steven Seitz, Vince McGonagle, Robert Pease, Mark Higgins
Visitor(s)
Daniel Waldman of Arnold & Porter on behalf of National Petrochemical and Refiners Association, Gregory Scott, National Petrochemical and Refiners Association, Tim Hogan, National Petrochemical and Refiners Association, Robert Long, Covington & Burling on behalf of American Petroleum Institute, Janice Raburn, American Petroleum Institute.
Organization(s)
American Petroleum Institute.
National Petrochemical and Refiners Association.
National Petrochemical and Refiners Association.