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External Meetings: Definitions Meeting with Gavilon
  
    



  In the meeting, Gavilon said that the final rule defining “swap dealer” should clarify when a company that uses swaps for more than one purpose would be deemed a swap dealer.  In particular, Gavilon explained that it uses swaps primarily to hedge commercial risks related to its agricultural commodity and energy commodity businesses, but that it also occasionally uses swaps to seek a proprietary profit.  Gavilon said the final definition should provide that a company would not necessarily be a swap dealer simply because it uses swaps for purposes other than to hedge commercial risk, and that the final definition should account for the difficulty of pinpointing precisely the purpose of each swap a company may use.  Gavilon also said that the de minimis exception from the swap dealer definition should allow for meaningful use of swaps for various business purposes without necessarily requiring registration as a swap dealer.
      
  When
              05/11/2011

  Rulemaking(s)
              II. DefinitionsXIX. Agricultural Swaps

  CFTC Staff
              Mark FajfarJulian HammarDavid AronChristopher CummingsSteve KaneRose TroiaDon HeitmanGreg KuserkBruce FekratRyne Miller

  Visitor(s)
              Dennis Stieren (Gavilon LLC)Ed Prosser (Gavilon LLC)Lance Kotschwar (Gavilon LLC)Scott Parsons (Delta Strategy Group)Graham Harper (Delta Strategy Group)Jeff Dinwoodie (SEC)Josh Kans (SEC)

  Organization(s)
              Gavilon LLCDelta Strategy Group

  Related Links
          Gavilon Handout 1
          Gavilon Handout 2  RELATED LINKS
    

      Gavilon Handout 1
          Gavilon Handout 2


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