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Capital and Margin Requirements for Covered Swap Entities

Dear Mr. Van Meter:

On behalf of The Commercial Energy Working Group (the “Working Group”), Sutherland Asbill & Brennan LLP hereby submits the attached comments (RIN3064 AD-79).  The Working Group is a diverse group of commercial firms in the energy industry whose primary business activity is the physical delivery of one or more energy commodities to others, including industrial, commercial, and residential consumers.  Members of the Working Group are energy producers, marketers, and utilities.  The Working Group considers and responds to requests for comment regarding regulatory and legislative developments with respect to the trading of energy commodities, including derivatives and other contracts that reference energy commodities. 

 The Working Group appreciates the opportunity to provide further comments on proposed regulations for the provision of margin in connection with swaps that parties do not submit for central clearing.  The Working Group has been an active participant in the rulemaking process regarding such margin practices and appreciates all your consideration in this process.

Respectfully submitted,

Katie Hoard | Commodities Regulatory Analyst

Sutherland Asbill & Brennan LLP
700 Sixth Street, NW, Suite 700 | Washington, DC 20001-3980
202.383.0829 direct | 202.637.3593 facsimile
katie.hoard@sutherland.com | www.sutherland.com

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Commercial Energy Working Group - Comment Letter on Margin and Capital.pdf - Commercial Energy Working Group - Comment Letter on Margin and Capital.pdf