IN: This is an email
Ken: In connection with our new product (and absence of any physical activity in that product), I have the following question: If neither ENA nor its counterparty is able to qualify as an offeree for purposes of the Trade Option Exemption (17 CFR Sec. 32.13, as amended) but each is an eligible swap participant (or better yet, each party has $10 million in net worth as per Sec. 32.13) can the option still be exempt from CFTC regulation under the Swap Policy Statement or any CFTC interpretive letters? I have concerns about not relying fully on the Trade Option Exemption but I also understood that the CFTC has informally said that the Swap Policy Statement provides a safe harbor for both swaps and options. I am available to speak at your convenience. Thanks. Sara [713/853-5620]

What is the subject?

OUT: Trade Option Exemption

IN: This is an email
Jim, as we discussed late last night I checked with all folks in the DC office who would have any conceivable reason to talk to Treasury. No one had a conversation yesterday where the SEC issue was discussed. Today, I have checked with the remainder of the DC office, and no one has had such a conversation. I hope this is helpful.

What is the subject?

OUT: Enron DC Office contacts with Treasury/SEC

IN: This is an email
Paul: I think you are trying to avoid me! Hope all is well and you are just overworked and overwhelmed. I am now working with Moazzam Khoja in Houston who is part of the enroncredit.com group most of which (as I understand) is located in London. In connection with that group's activities, I have some questions and all fingers point to you. (1) Do you have credit derivative research that may be applicable for credit derivative transactions (including your online "bankruptcy swap") in the US? I am sure that you've already explored the "insurance" issue and I don't want to duplicate reasearch, if possible. (2) What forms have you devised? Are they online? Should I just grab a password? (3) Are the enroncredit.com traders in the UK required by the SFA to take an SFA exam (I'm guessing it's a broker or securities exam)? Is trading in credit derivatives regulated, or regulated differently than other types of derivatives? I am trying to determine whether Moazzam needs to take the Series 7 here in the US; our traders taking that exam must be dealing in "securites" for that exam to be necessary. (4) Where is enroncredit.com headed? I would very much appreciate your [PROMPT] reply. Sara

What is the subject?

OUT:
credit derivatives/SFA exam