External Meetings: Meeting with Shell Oil Company

The meeting discussed the timing and implementation of the regulations under Dodd Frank in general, as well as the following points:~1) Definition of "swap" - how to distinguish forwards from physical options, how to treat instruments that may be regulated by the Federal Energy Regulatory Commission, how to treat derivatives on emissions certificates.~2) Position limits - Shell asserted that swaps between affiliates that constitute internal, risk allocating transactions should be aggregated and netted together before applying position limits.  Shell also asked for clarification regarding when a bona fide hedging exception from position limits would apply.~3) Definition of swap dealer - Shell asserted that participating in an electronic, anonymous market for swaps should not be viewed as swap dealing unless the participation is intended as part of a swap dealing business.  Overall, Shell said there should be a clear dividing line between activity that is considered to be dealing and activity that is not.