CFTC Ex Parte Meeting with Head of Supply Trading for BP (with Lofchie Comment)

CFTC staff met with representatives of British Petroleum to discuss the firm's calculations around the $8 billion de minimis exemption from swap dealer registration.

Lofchie Comment: Numerous firms are struggling to do these calculations given the uncertainty of both (i) what is a "swap" and (ii) what activities constitute "dealing." Of course, this is to say nothing of the still open question as to who is a "U.S. person."

Click here to see more details on the meeting.