For your information- please see below.

Sincerely,

Michelle Hershel
Director of Regulatory Affairs
Florida Electric Cooperatives Assoc.
2916 Apalachee Parkway
Tallahassee, FL  32301
(850)877-6166 ext.3
(850)656-5485 (fax)

-----Original Message-----
From: Russell Wasson [mailto:russell.wasson@nreca.coop]
Sent: Wednesday, June 08, 2011 10:39 AM
To: Finance Community Listserv
Subject: [fincom] CFTC Comment letter on 30 day reopener

From the Cooperative.com Finance Community Listserv:
Colleagues, we recently filed the attached comment letter with the CFTC.  As you may recall, there was a great deal of consternation expressed by many of the participants in the CFTC regulatory process concerning the lack of a defintion of the term "swap" which caused all of us to comment on numerous NOPRs without any idea of whether the NOPR might apply to us.  Chairman Gensler of the CFTC noted the concerns and suggested that the CFTC would reopen the comment period on a number of previously issued NOPRs to give folks an opportunity to submit comments after gaining more information about the product defintions.  Unfortunately, the NOPR on Product Defintions comment period does not end until July 22, so we still don't have a final rule on the definition of "swap" and we still don't know the extent of the CFTC's jurisdiciton over our industry.

However, we did respond to the 30 day repopener and suggested, among other things, that the CFTC consider a workshop for the entire electric industry, recognizing how different our industry is from other types of end users and their businesses.

Please let me know if you have any questions.

Russ

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