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External Meetings: Meeting with WSPP
  
    



  Participants discussed the interpretation in the product definitions concerning oral bookouts and the Brent Interpretation safe harbor for forward contracts.  WSPP representatives indicated that WSPP members generally would be in compliance with the interpretation’s requirement that oral bookouts be followed within a commercially reasonable timeframe by a confirmation in some type of written or electronic form.  WSPP raised a specific question about whether an electronic recording of a bookout would satisfy this requirement.  In addition, WSPP representatives  mentioned that members engage in volume bookouts, where multiple bookouts are documented in one transaction, rather than having to document each bookout separately, and inquired whether such volume bookouts would fall within the Brent Interpretation Safe Harbor.  Finally, existing language in the WSPP Agreement defining a bookout was discussed.
      
  When
              10/18/2012

  Rulemaking(s)
              XXI. Joint Rules w/ SEC

  CFTC Staff
              Terry ArbitDavid AronHerminio CastroLee Ann DuffyJulian HammarKenneth McCrackenGail ScottSomi SeongJason Shafer

  Visitor(s)
              Arnold Podgorsky, Wright & Talisman PCPatrick Morand, Wright & Talisman PC

  Organization(s)
              WSPP, Inc. (WSPP)Wright & Talisman, PC

  Related Links
          wspp_1937
          boc excerpt_1937  RELATED LINKS
    

      wspp_1937
          boc excerpt_1937


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