Created with Sketch.Menu Transparency
	Contact Us Search
Search
 Main navigation

      
      About the CFTC
                          The Commission
                        Chairman & Commissioners
                        CFTC Organization
                        Advisory Committees
                        Budget & Performance
                        Privacy at the CFTC
                        Careers
                        Diversity and Inclusion at the CFTC
                        Industry Oversight
                          Industry Filings
                        Trading Organizations
                        Clearing Organizations
                        Data Repositories
                        Intermediaries
                        Market Surveillance
                        Contracts & Products
                        Rules & Rule Amendments
                        Anti-Money Laundering
                        Law & Regulation
                          Commodity Exchange Act & Regulations
                        How Rules Are Made
                        Holding Wrongdoers Accountable
                        Federal Register
                        Public Comments
                        CFTC Staff Letters
                        Office of Technology Innovation
                        Market Data & Economic Analysis
                          Data at CFTC
                        Commitments of Traders
                        Bank Participation Reports
                        Cotton On-Call
                        Financial Data for FCMS
                        Net Position Changes Data
                        Staff Reports
                        Weekly Swaps Report
                        Cleared Margin Reports
                        Office of the Chief Economist
                        Forms & Submissions
                        Learn & Protect
                          Check Registration & Disciplinary History
                        Submit a Tip
                        Reparations Program
                        RED List
                        Advisories & Articles
                        Videos
                        Publications
                        News & Events
                          Press Releases
                        Public Statements & Remarks
                        Events Carousel Rotation On
              On


External Meetings: Definitions Meeting with BP
  
    



  BP explained that it can be difficult to separate its activities as an end user of swaps from its activities that may potentially constitute dealing in swaps.  As an end user, BP uses swaps to fix prices of its forward sales and purchases of oil, gasoline, diesel fuel and aircraft fuel.  Its use of swaps is part of an overall risk management program.~On the other hand, BP is approached by end users of swaps who are seeking to fix the prices of their forward sales and purchases.  In this respect, BP assists other parties in managing their risks.  BP engages in both of these activities in the same legal entity.~As for its swaps with end users, some are closely tied to (and may even be set out in the same document as) a particular sale or purchase of petroleum products, while other swaps are structured to provide for fixed prices over a long term.  BP frequently submits swaps for clearing.~BP is concerned that if it were a swap dealer, the applicable documentation and business conduct requirements would be a hindrance to BP’s customers in their use of swaps.  BP believes that many of the proposed requirements for swap dealers have not typically applied in the past to swaps related to petroleum products.  Since the requirements are unfamiliar to participants in the petroleum markets, there would be resistance to application of those requirements.  ~BP is also concerned that the proposed de minimis exception from the swap dealer definition does not set out a threshold that can be clearly applied in the petroleum markets.
      
  When
              01/27/2011

  Rulemaking(s)
              II. DefinitionsXXI. Joint Rules w/ SEC

  CFTC Staff
              Julian Hammar Lee Ann Duffy Mark Fajfar David AronSteve KaneSomi SeongNela Richardson

  Visitor(s)
              Andy P. Milnes (BP)Vincent B. Johnson (BP)

  Organization(s)
              BP


Resources

CFTC Regulations
	Commodity Exchange Act
	Privacy Policy
	Web Policy
	FOIA
	EEO Statement
	No Fear Act
	Accessibility Statement
	Procurement
	USA.gov
	Glossary

Actions

Search Public Comments
	Submit Tips & Complaints
	Search Industry FilingsWhistleblower.gov
	Office of Technology InnovationInspector GeneralSitemap

HomeCFTC Headquarters
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
202.418.5000