Paul: Here is the FSA letter with my comments inserted in red. I have tried to make it a bit stronger by deleting references to our positions being merely "arguable." The language I deleted in the first part of 3.4 I thought was unnecessary and just point out doors that may remain open for the SFA. The language added in 3.5 was an attempt to show how much EEFT does vs. EnronOnline. Is there a reason we are referring to Net Works rather than EnronOnline LLC? It is also a Delaware limited liability company. Are we afraid it may have a I also wonder if the discussion of EPOL's involvement in 2.2 and 4.2 is really needed since the ETA is entered into on EEFT's behalf. If this has not yet been raised by the SFA, it doesn't seem necessary to flag it for them. My position would be that EEFT is a party to that agreement whenever it is necessary in connection with an investment. Mark
Answer: FSA Letter
Hi Dee Dee OK, It is at about this point in time when my thoughts turn to my next vacation. Jeez, criminy (little Seattle lingo) have I been busy this week. Looking forward to the weekend to chill out a little. No big plans but to enjoy the college football extravaganza on Saturday. Maybe grill some beast depending on the weather and partake of a few sodas. It has been raining here all week which is good, because at least it isn't 107 degrees out. My clients in Denver wanted a full download on all my Cabo activities. These are the guys who have been to Cabo several times including the 20/20 club. As a matter of fact, the project I am working on right now for these guys is called Project 20/20. Coincidence, I don't think so. Anyway, when I told them I met this girl who went to 20/20 with me, they were very impressed. They now hold me in higher esteem than before. At least that's one way to gain the respect of your clients. So how is the great Northwest? Have your told grandparents about the wonderful time you had in Cabo with some strange guy walking around in your shoes. Some details are probably better left out. I am about out of here. Take care and I will talk to you later. Gerald
Answer: Next Vacation
FYI Per Sheila's inquiry and at Sara's direction, I called Ken Raisler at Cadwalader to determine if using the word "exchange" in a corporation's name would create any regulatory problems with the CFTC. Per Ken, there has been some historical sensitivity about the use of the word "exchange" . As we may have noticed though, a lot more companies are doing so without concern. He said there was no regulatory problem with the CFTC in using "exchange" in your corporate name, however, putting "exchange" in a company's name may put you on the CFTC's radar and get you more scrutiny. He also said that there may be regulatory conerns in Singapore and Hong Kong, so if we ever anticipate doing business there, it might not be a good idea.
Answer: Use of "exchange" in corporate name
Kroum has developed a new Forward Obligation Report, which will allow us to capture all term deals, desk-to-desk and all scheduling changes. Both Heather Dunton and I have tested it in stage and will be pushed out to production soon. Once I have the date I will forward it to all of you. It should be within the next couple of days. I will also show all of you how to run the report to capture the criteria we need to do our swaps. diana
Answer:
Forward Obligation Report