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secretary 

From: 

Sent: 

To: 

Subject: 

bob.turner@bache.com 

Friday, January 04, 2008 9:45 AM 

secretary 

ICE Clear 4(c) Request 

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RECEIVED 

C,F.lC. 

1 JAN -Q PH 5: 21 

., CORD vECTION ·• '· . 

COMMENT 

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David A. Stawick, Secretary 

Commodity Futures Trading Commission 

Three Lafayette Center 

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1155 21st Stre et, N. W. ( /' '"-: -~

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Washington , D. C. 20581 

RE: ICE CLEAR SECTION 4(C ) REQUEST 

;:--.:, 

Dear Mr. Stawick: "2: 

0 

I am writing t o voice my s upport for ICE Cl ear U.S. Inc. and I CE Futures U. 

S., Inc .' s exemption requests related t o their plans to clear o ver the counter swap 

transactions in sugar, coffee and cocoa , as published in the Federal Register on De c ember 

6, 20 07, at 72 F.R. 68 8 62 . 

I support ICE's pla n to offer OTC swap market parti cipants the ability to s ubstitute a 

swap position for a cleared- only, cash- settled futures contract, a s this wil l offer such 

OTC market p a rticipants additional flexibility i n managing their overal l position. I also 

support ICE's reque s t tha t Floor Members, subjec t to c ertain conditions, b e deemed ESPs 

for t he purpose of entering into the OTC t ransacti ons, as described i n the reque st for 

exemption. 

Further, I beli eve the exemption requests are approp riate to this goal , and that granting 

the exemption request will therefore b e nefit partic ipants in t h e OTC swap market. In 

addition, I be lieve tha t granting the rel ief requested wi ll not affect the ability of ICE 

Clear US or I CE Fut ures US to satisfy t he ir respective self- regul atory duties under the 

Commodity 

Exchange Act (the "Act '' ) or affect the ability of the Commission to 

fulfill its regulatory obligation unde r the Ac t. 

Be yond these specific exemp tio n requests, 

distinctions that treat a g r i c ultural swap 

no n - agricultural p roducts are unnecessary 

flexibility in the agricultural markets . 

in its future regulatory i n terpretations 

agric ultural swaps wherever possible. 

I also believe that the current regul a tory 

contracts differently than swap contracts in 

and ha ve the effe ct o f limiting innovation and 

Therefo re, I request t ha t the Commission support 

harmonious treatment o f agricul tural and n onIn closing, I believe that all of the conditions f or t he exercise of the Commiss ion's 

Exemptive Authority under Section 4 (c ) are met by the ICE proposals and t hey should be 

granted in all respects . 

Sincerel y, 

Robert Turner 

Senior Vice President 

Prudential Bache Commodi ties 

Robert Tu r ner 

Prudential Bache Commodities, LLC 

1 
440 South LaSalle Suite 2200 

Chicago, IL 60605 

bob.turner@bache.com 

office # 312-588-5140 

mobile # 312-505-2227 

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