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External Meetings: Meeting with Representatives of Pension Fund Company Sponsors and Pension Fund Trade Organizations
  
    



  The external attendees expressed views on the following issues: ~(i) Coordination of the CFTC’s proposed business conduct standards rules and the Department of Labor’s proposed definition of the term “fiduciary.”;  ~(ii) The interpretation of the phrase “best interests” in Section 4s(h)(4) of the Commodity Exchange Act (“CEA”);~(iii) ERISA plans and Section 4s(h)(5) of the CEA;~(iv) Reliance on the representations of the ERISA plan regarding the qualifications of its representative;~(v) Issues regarding the Know Your Counterparty rule;~(vi) Collective investment vehicles and the definition of Special Entities;~(vii) Timing of disclosure;~(viii) The effect of a claim that an ERISA plan’s representation to a swap dealer or major swap participant is incorrect. ~ ~The Pension Industry Representatives memorialized their views in their comment letters to the Commission which were placed in the public comment file.  Those comment letters are: Letter from Lynn Dudley, American Benefits Council & The Committee on Investment of Employee Benefit Assets, to David Stawick, Secretary, CFTC (Feb. 22, 2011); and Letter from Kent Mason, Davis & Harman LLP et. al, to David Stawick, Secretary, CFTC (Feb. 22, 2011).
      
  When
              02/10/2011

  Rulemaking(s)
              III. Business Conduct Standards w/ Counterparties

  CFTC Staff
              Tim KarpoffPhyllis CelaPeter SanchezKatie DriscollTed KnellerVivek Jain

  Visitor(s)
              Peter Y. Malyshev (Winston & Strawn LLP)Charles Van Vleet (United Technologies)Sharon Cassidy (U.S. Steel & Carnegie Pension Fund)Bill Donovan (U.S. Steel & Carnegie Pension Fund)Bella Sanevich (NISA Investment Advisors, LLC)Kent Mason (Davis & Harman/American Benefits Council)Jim Harshaw (Committee on Investment of Employee Benefit Assets (CIEBA))Mark Young (Skadden, Arps)Ken Porter (American Benefits Council (ABC))

  Organization(s)
              Winston & Strawn LLPUnited TechnologiesU.S. Steel & Carnegie Pension FundNISA Investment Advisors, LLCDavis & Harman LLPAmerican Benefits Council (ABC)Committee on Investment of Employee Benefit Assets (CIEBA)Skadden, Arps


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