APPA members invited to take survey on Dodd-Frank rules' impact on gas markets
Originally published May 1, 2013
The Committee of Chief Risk Officers (CCRO) has invited APPA members to participate in a short survey—a few yes/no questions—on liquidity in natural gas markets. The CCRO's Working Group on "Next Steps for Risk and Compliance under Dodd-Frank" developed the survey in order to document gas market participants’ experiences with liquidity changes in natural gas markets within the last six to nine months (that is, as the Commodity Futures Trading Commission began implementing major regulations under the derivatives title of the Dodd-Frank Act). Responses to the survey will "facilitate a discussion about monitoring for unintended consequences to liquidity," the CCRO said.
APPA is encouraging those public power utilities that use natural gas swaps to participate in the survey, which includes a question on the special entity threshold issue. Under CFTC regulations that define public power utilities as "special entities," a non-financial entity entering into as little as $25 million in swap transactions with government-owned utilities risks being defined as a swap dealer and drawn into the swap dealer regulatory regime. Otherwise, an entity may engage in up to $8 billion in swap dealing activity (phasing down to $3 billion over time) without being considered a swap dealer by the CFTC. As a result, some non-financial entities have stopped entering into such transactions with government-owned utilities.
The CCRO survey is available online.
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