Comments of the Center for Resource Solutions (“CRS”) to the Commodity Futures Trading Commission (“CFTC”) and Securities and Exchange Commission (“SEC”) on Notice of Proposed Rulemaking; Request for Comments on Further Definition of “Swap,” “Security-Based Swap,” e.t.c., (17 CFR Part 23, RIN 3038 AC96 Pursuant to Section 750 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”)

  • Author: Robin Quarrier, JP Rose, Jennifer Martin
  • Date: July 22nd, 2011| Comment | 13 Pages
  • The intent of these comments is to introduce CRS as an interested party, to describe the services that we provide for the voluntary over-the-counter (“OTC”) market for environmental commodities through our Green-e Energy and Green-e Climate certification and consumer-protection programs, and to provide comments on the Joint Notice of Proposed Rulemaking Request (“JNOPR”) for comments on further definition of “SWAP” pursuant to Section 721 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Specifically, in response to question 32 on page 29832 of Federal Register/Volume 76 No. 99, we believe that environmental commodities such as renewable energy certificates (“RECs”) and carbon offsets (“offsets”) are nonfinancial commodities that qualify under the forward contract exclusion from the swap definition.

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