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Enron Mail |
Cc: leonardo.pacheco@enron.com, carl.carter@enron.com, justin.rostant@enron.com,
andy.zipper@enron.com, savita.puthigai@enron.com Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit Bcc: leonardo.pacheco@enron.com, carl.carter@enron.com, justin.rostant@enron.com, andy.zipper@enron.com, savita.puthigai@enron.com X-From: David Forster X-To: Mark Taylor X-cc: Leonardo Pacheco, Carl Carter, Justin Rostant, Andy Zipper, Savita Puthigai X-bcc: X-Folder: \Mark_Taylor_Jun2001\Notes Folders\All documents X-Origin: Taylor-M X-FileName: mtaylor.nsf Mark, Thank you for the attached information on the impact of EnronOnline becoming "Regulated". I would appreciate it if you could confirm my understanding of the following points, which I took from our conversation yesterday: - It is possible that EnronOnline could become "regulated" as soon as a third party company manages a product which is the same as a Product which Enron (or another company) is managing, even if the product is physical. You are going to investigate and confirm whether or not this applies both to physical and financial products or financial only. - If we become "regulated", the regulations would apply only to the Product(s) in which more than one company is posting. In other words, by inviting a 3rd party company to manage a product which is the same as one managed by Enron, we invite regulation only for that Product. The rest of EnronOnline is unaffected. - The impacts of becoming "regulated" are spelled out in your attached document, but the primary impact is additional reporting requirements to the CFTC. - There are no additional issues associated with posting FX products (as far as Enron is concerned), but any bank posting their products will need to ensure they are compliant with any regulations affecting their activities and appropriate reps and warranties to this effect would need to be added to our contract with them. - It is your opinion that the reporting requirements imposed by the CFTC would not be such that Enron would be required to reveal sensitive information such as volume of buys or volume of sells to market (but it is possible that we may be required to add buys and sells together to report total transaction volume). - The $10 million capital adequacy requirement for companies transacting on financial products is unchanged, whether we are regulated or unregulated. Thanks, Dave -----Original Message----- From: Taylor, Mark Sent: Friday, April 27, 2001 3:32 PM To: Forster, David; Zipper, Andy Cc: Greenberg, Mark Subject: Electronic Trading Facilities for Transaction in Exempt Commodities Attached is a brief outline of the requirements for electronic trading facilities for transactions in exempt commodities. Exempt commodities are all commodities other than financial commodities (e.g. interest rates, currencies, securities) and agricultural commodities.
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