Certain Natural Gas and Electric Power Contracts, 20583-20587 [2016-08076]
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Federal Register / Vol. 81, No. 68 / Friday, April 8, 2016 / Proposed Rules
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Agenda for the Meetings
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—Sign-in
—Presentation of Meeting Procedures
—Informal Presentation of the Planned
Class B Airspace Area Modifications
—Solicitation of Public Comments
—Stations of Interest on Class B
airspace area modification
—Drop box for written comments
Authority: 49 U.S.C. 106(f), 106(g); 40103,
40113, 40120; E.O.10854, 24 FR 9565, 3 CFR,
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Issued in Washington, DC, on April 4,
2016.
Gemechu Gelgelu,
Acting Manager, Airspace Policy Group.
[FR Doc. 2016–08124 Filed 4–7–16; 8:45 am]
BILLING CODE 4910–13–P
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COMMODITY FUTURES TRADING
COMMISSION
17 CFR Part 1
SECURITIES AND EXCHANGE
COMMISSION
17 CFR Part 241
[Release No. 33–10062; 34–77506; File No.
S7–05–16]
RIN 3235–AL93
Certain Natural Gas and Electric Power
Contracts
Commodity Futures Trading
Commission; Securities and Exchange
Commission.
ACTION: Proposed guidance.
AGENCY:
In accordance with section
712(d)(4) of the Dodd-Frank Wall Street
Reform and Consumer Protection Act
(the ‘‘Dodd-Frank Act’’), the Commodity
Futures Trading Commission (the
‘‘CFTC’’) and the Securities and
Exchange Commission (‘‘SEC’’), after
consultation with the Board of
Governors of the Federal Reserve
System (‘‘Board of Governors’’), are
jointly issuing the CFTC’s proposed
guidance on certain contracts that
provide for rights and obligations with
respect to electric power and natural
gas. The CFTC invites public comment
on all aspects of its proposed guidance.
DATES: Comments must be received on
or before May 9, 2016.
ADDRESSES: You may submit comments
by any of the following methods:
• CFTC Web site: https://
comments.cftc.gov. Follow the
instructions for submitting comments
through the Comments Online process
on the Web site.
• Mail: Send to Christopher
Kirkpatrick, Secretary of the
Commission, Commodity Futures
Trading Commission, Three Lafayette
Centre, 1155 21st Street NW.,
Washington, DC 20581.
• Hand Delivery/Courier: Same as
Mail, above.
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
Please submit your comments using
only one of these methods.
All comments must be submitted in
English, or if not, accompanied by an
English translation. Comments will be
posted as received to www.cftc.gov. You
should submit only information that
you wish to make available publicly. If
you wish the CFTC to consider
information that you believe is exempt
from disclosure under the Freedom of
SUMMARY:
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20583
Information Act, a petition for
confidential treatment of the exempt
information may be submitted according
to the procedures established in § 145.9
of the CFTC’s regulations, 17 CFR 145.9.
The CFTC reserves the right, but shall
have no obligation, to review, prescreen, filter, redact, refuse or remove
any or all of a submission from
www.cftc.gov that it may deem to be
inappropriate for publication, such as
obscene language. All submissions that
have been redacted or removed that
contain comments on the merits of the
notice will be retained in the public
comment file and will be considered as
required under all applicable laws, and
may be accessible under the Freedom of
Information Act.
FOR FURTHER INFORMATION CONTACT:
CFTC: David N. Pepper, Special
Counsel, Division of Market Oversight,
at (202) 418–5565 or dpepper@cftc.gov;
or Mark Fajfar, Assistant General
Counsel, Office of the General Counsel,
at (202) 418–6636 or mfajfar@cftc.gov,
Commodity Futures Trading
Commission, Three Lafayette Centre,
1155 21st Street NW., Washington, DC
20581. SEC: Carol McGee, Assistant
Director, Office of Derivatives Policy,
Division of Trading and Markets, at
(202) 551–5870, Securities and
Exchange Commission, 100 F Street NE.,
Washington, DC 20549.
SUPPLEMENTARY INFORMATION:
I. Introduction
In the final rule further defining the
term ‘‘swap,’’ the CFTC and the SEC
adopted an interpretation regarding the
facts and circumstances in which
certain agreements, contracts, or
transactions entered into by commercial
and non-profit entities should be
considered not to be swaps because they
are customary commercial
arrangements.1 Following adoption of
this interpretation, the CFTC received
public comments describing certain
types of contracts that are closely tied to
regulatory obligations in the markets for
electric power and natural gas.2
1 See Further Definition of ‘‘Swap,’’ SecurityBased Swap,’’ and ‘‘Security-Based Swap
Agreement’’; Mixed Swaps; Security-Based Swap
Agreement Recordkeeping, 77 FR 48207, 48246
(Aug. 13, 2012) (the ‘‘Products Release’’).
2 The comments were received in response to the
CFTC’s proposed interpretation on Forward
Contracts With Embedded Volumetric Optionality,
79 FR 69073 (Nov. 20, 2014) (comments available
at https://comments.cftc.gov/PublicComments/
CommentList.aspx?id=1541), and the CFTC’s notice
of proposed rulemaking on Trade Options, 80 FR
26200 (May 7, 2015) (comments available at
https://comments.cftc.gov/PublicComments/
CommentList.aspx?id=1580). In addition, the
CFTC’s Energy and Environmental Markets
Advisory Committee discussed related issues at its
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Federal Register / Vol. 81, No. 68 / Friday, April 8, 2016 / Proposed Rules
Having reviewed these comments, the
CFTC proposes to issue guidance
regarding particular facts and specific
circumstances in which these contracts
should be considered not to be ‘‘swaps’’
for purposes of the Commodity
Exchange Act (‘‘CEA’’).3 This proposed
guidance applies the interpretation in
the Products Release to the contracts
described in Part II.A. of this document
and the CFTC preliminarily concludes
that such contracts should be
considered not to be swaps because they
are customary commercial
arrangements.
II. Proposed Guidance
A. Commenters’ Description of Certain
Contracts
Commenters described two types of
contracts that are similar in some
respects, but are used in different
situations to provide for rights and
obligations that are suitable to the
parties’ particular needs in those
situations, and which are closely tied to
compliance with certain regulatory
requirements and frameworks. Each is
described briefly below.
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1. Certain Capacity Contracts—Electric
Power
The CFTC understands that certain
types of capacity contracts in electric
power markets are used in situations
where regulatory requirements from a
state public utility commission (‘‘PUC’’)
obligate load serving entities (‘‘LSEs’’)
and load serving electric utilities in that
state to purchase ‘‘capacity’’ (sometimes
referred to as ‘‘resource adequacy’’) 4
from suppliers to secure grid
management and on-demand
deliverability of power to consumers. A
meeting on July 29, 2015 (transcript available at
https://www.cftc.gov/PressRoom/Events/opaevent_
eemac072915).
3 See 7 U.S.C. 1a(47). This proposed guidance is
being issued jointly with the SEC pursuant to
section 712(d)(4) of the Dodd-Frank Act but, given
the specific types of contracts at issue, pertains only
to the CFTC and swaps. Because the proposed
guidance is limited to the particular facts and
circumstances of the contracts at issue, the
proposed guidance, if adopted, would not pertain
to the SEC or security-based swaps.
4 The resource adequacy framework adopted by
the California Public Utilities Commission
(‘‘CPUC’’) is an illustrative example. The CPUC
adopted a resource adequacy policy framework in
2004 in order to ensure the reliability of electric
service in California. The CPUC established
resource adequacy obligations applicable to all
LSEs within the CPUC’s jurisdiction. The CPUC’s
resource adequacy policy framework—implemented
as the Resource Adequacy program—guides
resource procurement and promotes infrastructure
investment by requiring that LSEs procure capacity
so that capacity is available to the California
Independent System Operator (‘‘ISO’’) when and
where needed. See generally the discussion of
resource adequacy available at https://
www.cpuc.ca.gov/ra/.
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commenter explained that the LSE or
load serving electric utility will be
recognized by the PUC and the Federal
Energy Regulatory Commission
(‘‘FERC’’) as having purchased capacity
and, therefore, having satisfied that
portion of its obligation to purchase the
ability to supply the electricity when
and as needed.5 In each of these
instances, a commenter asserted, the
purchaser, as required by law, will be
considered to have purchased the
supplier’s capacity to generate, produce
and deliver electric power, regardless of
whether the electricity underlying the
capacity contract is called upon and
delivered.6
A commenter said the purchaser does
not treat this type of capacity contract
as a ‘‘hedge’’ in the same sense as it
would otherwise use a commodity
option as a financial hedge.7 In this type
of capacity contract, the commenter
contended, the purchaser is not
procuring the right to profit from a
change in the value of the underlying
commodity, which the purchaser will
then financially settle in order to offset
the price volatility risk of some
underlying physical transaction in the
cash market.8 Rather, the purchaser is
purchasing a supplier’s capacity to
produce, generate, and deliver the
underlying electricity, thereby ensuring
its ability to supply electricity in
compliance with a regulatory
requirement.9 Certain commenters
explained that they do not view these
contracts as financial instruments, but
rather as commercial agreements that
enable the purchaser of capacity to
ensure that the underlying electricity is
delivered when needed by the
purchaser to meet state- and/or
federally-required reliability
objectives.10 One commenter stated that
state PUCs and the FERC generally do
not treat a purchase of capacity in this
context as a purchase of a financial
5 See letter from International Energy Credit
Association (‘‘IECA’’) (June 22, 2015) at 9. The
CFTC understands that this type of contract enables
a Regional Transmission Organization (‘‘RTO’’) or
ISO to call on resource adequacy capacity to ensure
the reliability of electric service to end users or
consumers. The LSE or load serving electric utility,
which is required to purchase capacity contracts,
cannot itself call on the supplier to deliver
electricity—only the RTO or ISO can.
6 See id.
7 See id.
8 See id.
9 One commenter contended that although this
type of capacity contract may not impose a binding
obligation on the parties to make and take delivery
of a specific quantity of electricity, it does impose
a binding obligation on the parties to make and take
delivery of the capacity. See id. at 10.
10 See letter from IECA (June 22, 2015) at 10, and
letter from Coalition for Derivatives End-Users
(‘‘CDEU’’) (Dec. 22, 2014) at 7–8.
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instrument or an option, but rather as a
purchase of the ability to ensure
delivery of the underlying physical
commodity.11
A commenter explained how the
payment structure under a capacity
contract for resource adequacy is
different from the payment structure
under a financially-settled commodity
option. According to this commenter,
capacity contracts do not involve
payment of a nominal option premium,
followed by payment of the full market
price of the electric power if and when
the ‘‘option’’ is exercised.12 Instead, the
initial payment under the capacity
contract frequently recovers for the
seller the entire fixed cost of producing,
generating, supplying or transmitting
the electric power.13
2. Certain Peaking Supply Contracts—
Natural Gas
Commenters requested further
guidance on whether certain natural gas
contracts, which commenters labeled as
‘‘peaking supply contracts,’’ and which
are entered into by electric utilities
(with or without a minimum gas
delivery requirement) should be
regulated as swaps.14 The CFTC
understands a peaking supply contract
in this context to be a contract that
enables an electric utility to purchase
natural gas from another natural gas
provider on those days when its local
natural gas distribution companies
(‘‘LDCs’’) curtail its natural gas
transportation service. For example, one
commenter, Linden, explained that it
procures sufficient natural gas and gas
transportation services to operate its
cogeneration facility in the ordinary
course through natural gas service
agreements with its LDCs.15 Linden
11 See
letter from IECA (June 22, 2015) at 10.
id. at 11.
13 See id. Resource adequacy capacity is not tied
to a specific power price and the purchaser of
capacity does not have access to the energy tied to
the capacity requirement. The capacity purchased
is essentially conferred or assigned to the RTO or
ISO, and these entities can call the capacity.
14 See letter from American Gas Association
(‘‘AGA’’) (Dec. 22, 2014) at 9–11, letter from AGA
(June 22, 2015) at 2–5; and letter from Cogen
Technologies Linden Venture, L.P. (‘‘Linden’’) (June
22, 2015) at 2–3. For purposes of this proposed
guidance, the term electric utility means ‘‘all
enterprises engaged in the production and/or
distribution of electricity for use by the public,
including investor-owned electric utility
companies; cooperatively-owned electric utilities;
government-owned electric utilities (municipal
systems, federal agencies, state projects, and public
power districts).’’ See Federal Energy Regulatory
Commission (FERC) Glossary, available at https://
ferc.gov/resources/glossary.asp.
15 Linden is an exempt wholesale generator
selling electric power at market-based rates under
the jurisdiction of the FERC, and owns and operates
a combined cycle natural gas-fired cogeneration
facility located in Linden, New Jersey. The
12 See
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explained that its natural gas service
agreements require Linden to take
natural gas from the LDCs if they supply
it. However, to ensure that the LDCs are
able to meet their regulatory
commitments to prioritize and serve
residential demand for natural gas, the
local board of public utilities (‘‘BPU’’)
requires that the service agreements
permit the LDCs to interrupt natural gas
transportation service to Linden during
certain specified conditions.16 Due to
the LDCs’ tariff-based commitments to
serve residential natural gas demand,
the BPU will not allow the LDCs to
provide a ‘‘firmer’’ category of natural
gas service to Linden.17 Because of the
possibility of these interruptions of
transportation service, Linden uses
peaking supply contracts to ensure it
has sufficient natural gas to operate its
cogeneration facility during the
interruptions.18
Linden represented that, under its
natural gas service agreements, the LDCs
determine when the conditions for
interrupting Linden’s service are
present, and Linden therefore has no
control over such conditions. Thus,
Linden does not have discretion as to
whether and when an interruption of
service as described above will occur.19
Linden explained that, under the
terms of its natural gas service
agreements, Linden is required to take
natural gas from the LDCs if they supply
it. There is no ability for financial
settlement under Linden’s peaking
supply contracts, and natural gas
supplied under those peaking supply
contracts cannot be re-sold by Linden.20
Linden represented that the price for
natural gas in its peaking supply
contracts is based on the market cost of
fuel at specified delivery points, plus a
specified adjustment depending on
delivery point.21 Thus, since Linden
could not use that natural gas for any
purpose other than to fuel its facility
when an interruption of service occurs,
Linden represented that it is practically
limited to exercising its right to take
delivery under its peaking supply
electricity produced from Linden’s generator is
sold, under a long-term power purchase agreement,
to Consolidated Edison Company, which then uses
the power to serve the electricity needs of
consumers in New York City. Steam from Linden’s
operation is sold, also under a long-term contract,
to the co-located Bayway Refinery, the largest
refinery on the East Coast, for its industrial
processes. See letter from Linden (June 22, 2015) at
1–3.
16 See id.
17 See id.
18 See id.
19 See id. at 3.
20 See letter from Linden (Dec. 22, 2014) at 6.
21 See letter from Linden (June 22, 2015) at 4, n.
12.
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contracts only in the event of an
interruption of service, and that it has
no discretion as to whether and when it
will exercise the right to take delivery
under its natural gas peaking supply
contracts.22
3. Common Characteristics Described by
Commenters
As they have been described by
commenters, the natural gas and electric
power contracts discussed above are all
entered into by commercial market
participants, who contemplate physical
settlement of the transactions, in
response to regulatory requirements, the
need to maintain reliable supplies, and
practical considerations of storage or
transport.23 In each case, the particular
commodities covered by the contract are
needed by at least one of the parties for
the normal operation of its business,
and the specific identity of the
counterparty is an important
consideration because of, for example,
concerns about reliability or the
practicability of supply.24
B. Products Release Discussion of
Commercial Contracts
In the Products Release, the CFTC and
the SEC (the ‘‘Commissions’’) adopted
an interpretation to assist commercial
and non-profit entities in understanding
whether certain agreements, contracts,
or transactions that they enter into
would or would not be regulated as
swaps.25 To that end, the Products
Release listed several specific types of
commercial agreements, contracts, and
transactions that involve customary
business arrangements (whether or not
involving a for-profit entity) that will
not be considered swaps, including:
Employment contracts; sales, servicing,
or distribution arrangements; certain
fixed or variable interest rate
commercial loans or mortgages; and
certain agreements, contracts, or
transactions related to business
combination transactions, real property,
intellectual property, and warehouse
lending arrangements.26 The
Commissions stated their intent that this
interpretation should ‘‘allow
commercial and non-profit entities to
continue to operate their businesses and
operations without significant
disruption and provide that the swap
. . . definition [is] not read to include
commercial and non-profit operations
that historically have not been
considered to involve swaps.’’ 27
The Commissions also explained that
the list provided in the Products Release
was not intended to be exhaustive and
that there may be other, similar types of
agreements, contracts, and transactions
that also should not be considered to be
swaps.28 The Commissions said that in
determining whether similar types of
agreements, contracts, and transactions
entered into by commercial entities
should not be considered swaps, they
intend to consider the characteristics
and factors that are common to the
commercial transactions listed in the
Products Release, which are:
• They do not contain payment
obligations, whether or not contingent,
that are severable from the agreement,
contract, or transaction;
• They are not traded on an organized
market or over-the-counter; and . . .
• In the case of commercial
arrangements, they are entered into:
—By commercial or non-profit
entities as principals (or by their agents)
to serve an independent commercial,
business, or non-profit purpose, and
—Other than for speculative, hedging,
or investment purposes.29
The Commissions concluded that in
determining whether an agreement,
contract, or transaction not enumerated
in the Products Release is a swap, the
agreement, contract, or transaction will
be evaluated based on its particular facts
and circumstances,30 and the
representative characteristics and
factors set out in the Products Release
‘‘are not intended to be a bright-line test
for determining whether a particular
. . . commercial arrangement is a
swap.’’ 31
In the Products Release, the CFTC
also addressed certain capacity
contracts and peaking supply contracts
in the context of the CFTC’s
interpretation of when an agreement,
contract, or transaction with embedded
volumetric optionality would be
considered a forward contract.32 The
CFTC stated that depending on the
relevant facts and circumstances,
capacity contracts and peaking supply
contracts may qualify as forward
contracts with embedded volumetric
optionality if they met the elements of
the CFTC’s interpretation of that
provision.33 This remains the case; the
CFTC does not intend that the proposed
22 See
27 See
23 See
28 See
id. at 3–4.
letter from CDEU (Dec. 22, 2014) at 7, letter
from EDF Trading North America, LLC (Dec. 22,
2014) at 13.
24 See letter from AGA (Dec. 22, 2014) at 9.
25 See Products Release, 77 FR at 48246.
26 See id., 77 FR at 48247.
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20585
id.
id.
29 See id.
30 See id., 77 FR at 48248.
31 See id., 77 FR at 48250.
32 See id., 77 FR at 48238.
33 See id., 77 FR at 48240.
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guidance herein would affect the
interpretation of when an agreement,
contract, or transaction with embedded
volumetric optionality would be
considered a forward contract.34
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C. Proposed Guidance on Whether
Certain Contracts Should Be Considered
To Be Swaps
In response to the comments,
described above, which were provided
by market participants regarding certain
capacity contracts for electric power and
certain peaking supply contracts for
natural gas, the CFTC has considered
the specific facts and circumstances of
these contracts in light of the
interpretation in the Products Release of
when a contract would be considered
not to be a swap because it is a
customary commercial arrangement.
The CFTC understands, based on the
commenters’ descriptions, that the
contracts described in Part II.A. above
are not traded on an organized market
or over-the-counter, and do not have
severable payment obligations. Thus,
the CFTC preliminarily believes that the
contracts described in Part II.A. are
consistent with the first two elements of
the interpretation in the Products
Release.35
34 The CFTC has clarified this interpretation. See
Forward Contracts With Embedded Volumetric
Optionality, 80 FR 28239 (May 18, 2015). In this
clarification, the CFTC addressed certain retail
electric market demand-response programs, under
which electric utilities have the right to interrupt
or curtail service to a customer to support system
reliability. See id., 80 FR at 28242, citing letter from
the National Rural Electric Cooperative Association,
the American Public Power Association, the Large
Public Power Association, and the Transmission
Access Policy Study Group (Oct. 12, 2012) at 9.
The CFTC clarified that since a key function of
an electricity system operator is to ensure grid
reliability, demand response agreements, even if not
specifically mandated by a system operator, may be
properly characterized as the product of regulatory
requirements within the meaning of the seventh
element of the CFTC’s interpretation regarding
forward contracts with embedded volumetric
optionality. For the avoidance of doubt, the CFTC
reiterates that the proposed guidance herein would
not affect this interpretation.
Also, the CFTC’s interpretations regarding full
requirements and output contracts, as provided in
the Products Release, would be unaffected by the
proposed guidance herein. See Products Release, 77
FR at 48239–40.
Furthermore, the CFTC does not intend that the
proposed guidance would supersede or modify a
document issued by the CFTC’s Office of General
Counsel—‘‘Response to Frequently Asked
Questions Regarding Certain Physical Commercial
Agreements for the Supply and Consumption of
Energy,’’ available at https://www.cftc.gov/idc/
groups/public/@newsroom/documents/file/
leaselike_faq.pdf—which continues to be the
position of the CFTC’s Office of General Counsel on
the issues discussed in that document.
35 See Products Release, 77 FR at 48247 (the
contracts ‘‘do not contain payment obligations,
whether or not contingent, that are severable from
the agreement, contract, or transaction; [and] . . .
are not traded on an organized market or over-thecounter’’).
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The CFTC has also considered the
contracts described in Part II.A. in light
of the statement in the Products Release
that, in order not to be considered
swaps, the contracts should be entered
into ‘‘[b]y commercial or non-profit
entities as principals (or by their agents)
to serve an independent commercial,
business, or non-profit purpose, and
[o]ther than for speculative, hedging, or
investment purposes.’’ 36 In view of all
the facts and circumstances of the
contracts described in Part II.A., the
CFTC preliminarily believes that such
contracts would satisfy this element of
the Products Release, and therefore
should be considered not to be swaps
under the interpretation set forth in the
Products Release because they are
customary commercial arrangements of
the type described in the Products
Release.
The CFTC notes that commenters
have represented that the contracts
described in Part II.A. are entered into
in response to regulatory requirements,
the need to maintain reliable supplies,
and practical considerations of storage
or transport which arise in the course of
the normal operation of at least one
party’s business. In this respect, the
CFTC preliminarily believes that the
contracts described in Part II.A. are
similar to certain contracts—namely,
sales, servicing and distribution
arrangements, and contracts for the
purchase of equipment or inventory—
listed in the Products Release as
commercial contracts that will not be
considered swaps.37 Also, in the
Products Release the Commissions
addressed commenters’ assertion that all
commercial merchandising transactions
hedge an enterprise’s commercial risks
by stating that a commercial
arrangement undertaken for hedging
purposes may or may not be a swap
depending on the particular facts and
circumstances of the arrangement.38
The CFTC observes that when an
entity enters into a purchase contract, it
is assured of a supply of the equipment
or inventory it will need in the future.
Similarly, a service contract assures the
availability of a needed service in the
future. The contracts described in Part
II.A. are similar to the purchase and
service contracts enumerated in the
Products Release because they appear to
satisfy the elements of commercial
contracts, transactions or arrangements
that are not considered swaps, including
that they are entered into by commercial
or non-profit entities to assure
availability of a commodity, not to
36 See
id.
id.
38 See id., 77 FR at 48249.
hedge against risks arising from a future
change in price for the commodity or to
serve a speculative or investment
purpose.
As stated in the Products Release,
whether a particular commercial
arrangement is a swap depends on the
particular facts and circumstances of the
arrangement.39 This proposed guidance
would not apply to any agreement,
contract or transaction other than those
described in Part II.A., and would not
preclude the CFTC from issuing further
guidance considering other commodity
contracts under the interpretation in the
Products Release.
III. Request for Comment
The CFTC believes that it would
benefit from public comment about its
proposed guidance, and therefore
requests public comment on all aspects
of its proposed guidance set forth above,
and on the following questions:
1. Are there natural gas and electric
power contracts that would not qualify
as trade options within the scope of
CFTC regulation 32.3 but which would
be covered by the proposed guidance? If
so, should the proposed guidance be
limited so that it encompasses only
contracts that do qualify as trade
options? Why or why not?
2. Does the proposed guidance
provide sufficient clarity on whether the
specific types of natural gas and electric
power contracts in question should or
should not be considered to be swaps?
If not, how should the guidance be
revised to provide more clarity?
3. Are there other facts and
circumstances that the CFTC should
consider in determining whether the
contracts described in Part II.A. are
swaps? If so, what are these factors and
how should they be considered?
4. Are there contracts (other than
those described in Part II.A.) that are
entered into by participants in the
electric power and natural gas markets
and necessitated by, or closely tied to,
compliance with regulatory obligations
or frameworks that are similar to those
described in Part II.A.?
5. Are there other types of commodity
contracts, outside of the electric power
and natural gas markets, which are
necessitated by, or closely tied to,
compliance with regulatory obligations
or frameworks that should be
considered under the interpretation in
the Products Release? If so, please
describe these contracts and the
regulatory obligations and frameworks
to which they are closely tied.
6. Are there public interest
considerations regarding the natural gas
37 See
PO 00000
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Fmt 4702
Sfmt 4702
39 See
E:\FR\FM\08APP1.SGM
id., 77 FR at 48248.
08APP1
Federal Register / Vol. 81, No. 68 / Friday, April 8, 2016 / Proposed Rules
and electric power contracts in question
that should be reflected in the proposed
guidance? If so, why and how?
7. Does the proposed guidance
provide sufficient clarity that it does not
supersede or modify the CFTC OGC
FAQ referenced in footnote 34? Is there
any potential overlap between the
proposed guidance and the CFTC OGC
FAQ that should be further clarified? If
so, what elements of the proposed
guidance should be clarified to indicate
that the proposed guidance does not
supersede or modify the CFTC OGC
FAQ?
8. With respect to natural gas peaking
contracts, are there natural gas providers
other than LDCs, such as Intrastate and
Interstate Natural Gas Pipelines (as
those terms are defined by the Energy
Information Administration),40 which
are subject to regulatory obligations to
prioritize and serve residential demand
for natural gas, such that the providers
are obligated to curtail service to electric
utilities under certain circumstances? If
so, please explain.
By the Securities and Exchange
Commission.
Dated: April 4, 2016.
Brent J. Fields,
Secretary.
Issued in Washington, DC, on April 4,
2016, by the Commodity Futures Trading
Commission.
Christopher J. Kirkpatrick,
Secretary of the Commission.
26 CFR Part 1
[REG–135734–14]
RIN 1545–BL00; RIN 1545–BN30
On this matter, Chairman Massad and
Commissioners Bowen and Giancarlo voted
in the affirmative. No Commissioner voted in
the negative.
asabaliauskas on DSK3SPTVN1PROD with PROPOSALS
Partial Withdrawal of Proposed
Application of Section 367 to a Section
351 Exchange Resulting From a
Transaction Described in Section
304(a)(1); Partial Withdrawal of
Proposed Guidance for Determining
Stock Ownership
Internal Revenue Service (IRS),
Treasury.
ACTION: Partial withdrawal of notice of
proposed rulemaking.
AGENCY:
This document withdraws
portions of a notice of proposed
rulemaking published in the Federal
Register on February 11, 2009. The
withdrawn portions relate to the
application of section 367(b) to
transactions described in section
304(a)(1). This document also
withdraws portions of a notice of
proposed rulemaking published in the
Federal Register on January 17, 2014.
The withdrawn portions relate to the
identification of certain stock of a
foreign corporation that is disregarded
in calculating ownership of the foreign
corporation for purposes of determining
whether it is a surrogate foreign
corporation for purposes of section
7874.
SUMMARY:
Appendix 2—Statement of CFTC
Chairman Timothy G. Massad
Today, the CFTC and the Securities and
Exchange Commission (SEC), have jointly
proposed guidance relating to the appropriate
treatment of certain peaking supply and
capacity contracts. We are issuing this
guidance after considering the useful input
we have received from market participants
expressing concern about this issue. I support
this proposal, as it will properly clarify the
treatment of contracts used by many
businesses with respect to the supply and
delivery of electric power and natural gas.
40 See Distribution of Natural Gas: The Final Step
in the Transmission Process, Energy Information
Administration, Office of Oil and Gas, June 2008,
available at https://www.eia.gov/pub/oil_gas/
natural_gas/feature_articles/2008/ldc2008/
ldc2008.pdf.
Jkt 238001
BILLING CODE 6351–01–P;8011–01–P
Internal Revenue Service
Appendix 1—Commodity Futures
Trading Commission Voting Summary
18:31 Apr 07, 2016
[FR Doc. 2016–08076 Filed 4–7–16; 8:45 am]
DEPARTMENT OF THE TREASURY
Commodity Futures Trading
Commission (CFTC) Appendices to
Certain Natural Gas and Electric Power
Contracts—Commission Voting
Summary and Chairman’s Statement
VerDate Sep<11>2014
We have proposed that certain electric
power and natural gas contracts should not
be considered ‘‘swaps’’ under the Commodity
Exchange Act. We have done so because we
believe they are examples of customary
commercial arrangements as described in the
final rule defining the term ‘‘swap.’’
For example, these contracts are entered
into to assure availability of a commodity,
not to hedge against risks arising from a
future change in price of that commodity or
for speculative, or investment purposes. They
are typically entered into in response to
regulatory requirements, the need to
maintain reliable energy supplies, and
practical considerations of storage or
transport. All of these factors are consistent
with what has been set forth in previous
commission guidance.
Today’s proposed guidance is an important
complement to our final rule regarding Trade
Options, which will reduce burdens on endusers and allow them to better address
commercial risk. I thank my fellow
Commissioners Bowen and Giancarlo for
joining me in unanimously approving this
proposal as well as that final rule.
PO 00000
Frm 00013
Fmt 4702
Sfmt 4702
20587
As of April 8, 2016, portions of
proposed rules (REG–147636–08 and
REG–121534–12) published in the
Federal Register on February 11, 2009
(74 FR 6840) and January 17, 2014 (79
FR 3145) are withdrawn.
FOR FURTHER INFORMATION CONTACT:
Shane M. McCarrick or David A. Levine,
(202) 317–6937.
SUPPLEMENTARY INFORMATION:
DATES:
Background
On February 11, 2009, the Department
of Treasury (Treasury Department) and
the IRS published in the Federal
Register proposed regulations (REG–
147636–08, 74 FR 6840), including
§ 1.367(b)–4(e), (f), and (g), which
provide guidance on the application of
section 367(b) to transactions described
in section 304(a)(1). The regulations
were proposed by cross-reference to
temporary regulations in § 1.367(b)–4T
in the same issue of the Federal Register
(T.D. 9444, 74 FR 6824). This document
withdraws these proposed regulations
because the rules in the proposed
regulations do not reflect current law.
See Notice 2012–15, 2012–9 I.R.B. 424
(revising the approach under the
proposed regulations regarding the
interaction of sections 367 and 304 and
providing that section 367(a) and (b)
apply fully to certain transctions
described in section 304(a)(1)). In the
Rules and Regulations section of this
issue of the Federal Register, the
Treasury Department and the IRS are
issuing additional temporary regulations
in § 1.367(b)–4T(e), (f), and (g), as well
as (h), that, in the case of certain
exchanges, generally require an
inclusion of amounts in income as a
deemed dividend or recognition of
realized gain that is not otherwise
recognized, or both. Accordingly, the
Treasury Department and the IRS are
issuing a notice of proposed rulemaking
in the Proposed Rules section of this
issue of the Federal Register that
proposes new rules in § 1.367(b)–4T by
cross-reference to the temporary
regulations.
On January 17, 2014, the Treasury
Department and the IRS published in
the Federal Register proposed
regulations (REG–121534–12, 79 FR
3145), including in § 1.7874–4, that
provide that certain stock of a foreign
corporation is disregarded in calculating
ownership of the foreign corporation for
purposes of determining whether it is a
surrogate foreign corporation for
purposes of section 7874. The
regulations were proposed by crossreference to temporary regulations in
§ 1.7874–4T in the same issue of the
Federal Register (T.D. 9654, 79 FR
E:\FR\FM\08APP1.SGM
08APP1
Agencies
[Federal Register Volume 81, Number 68 (Friday, April 8, 2016)]
[Proposed Rules]
[Pages 20583-20587]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-08076]
=======================================================================
-----------------------------------------------------------------------
COMMODITY FUTURES TRADING COMMISSION
17 CFR Part 1
SECURITIES AND EXCHANGE COMMISSION
17 CFR Part 241
[Release No. 33-10062; 34-77506; File No. S7-05-16]
RIN 3235-AL93
Certain Natural Gas and Electric Power Contracts
AGENCY: Commodity Futures Trading Commission; Securities and Exchange
Commission.
ACTION: Proposed guidance.
-----------------------------------------------------------------------
SUMMARY: In accordance with section 712(d)(4) of the Dodd-Frank Wall
Street Reform and Consumer Protection Act (the ``Dodd-Frank Act''), the
Commodity Futures Trading Commission (the ``CFTC'') and the Securities
and Exchange Commission (``SEC''), after consultation with the Board of
Governors of the Federal Reserve System (``Board of Governors''), are
jointly issuing the CFTC's proposed guidance on certain contracts that
provide for rights and obligations with respect to electric power and
natural gas. The CFTC invites public comment on all aspects of its
proposed guidance.
DATES: Comments must be received on or before May 9, 2016.
ADDRESSES: You may submit comments by any of the following methods:
CFTC Web site: https://comments.cftc.gov. Follow the
instructions for submitting comments through the Comments Online
process on the Web site.
Mail: Send to Christopher Kirkpatrick, Secretary of the
Commission, Commodity Futures Trading Commission, Three Lafayette
Centre, 1155 21st Street NW., Washington, DC 20581.
Hand Delivery/Courier: Same as Mail, above.
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
Please submit your comments using only one of these methods.
All comments must be submitted in English, or if not, accompanied
by an English translation. Comments will be posted as received to
www.cftc.gov. You should submit only information that you wish to make
available publicly. If you wish the CFTC to consider information that
you believe is exempt from disclosure under the Freedom of Information
Act, a petition for confidential treatment of the exempt information
may be submitted according to the procedures established in Sec. 145.9
of the CFTC's regulations, 17 CFR 145.9.
The CFTC reserves the right, but shall have no obligation, to
review, pre-screen, filter, redact, refuse or remove any or all of a
submission from www.cftc.gov that it may deem to be inappropriate for
publication, such as obscene language. All submissions that have been
redacted or removed that contain comments on the merits of the notice
will be retained in the public comment file and will be considered as
required under all applicable laws, and may be accessible under the
Freedom of Information Act.
FOR FURTHER INFORMATION CONTACT: CFTC: David N. Pepper, Special
Counsel, Division of Market Oversight, at (202) 418-5565 or
dpepper@cftc.gov; or Mark Fajfar, Assistant General Counsel, Office of
the General Counsel, at (202) 418-6636 or mfajfar@cftc.gov, Commodity
Futures Trading Commission, Three Lafayette Centre, 1155 21st Street
NW., Washington, DC 20581. SEC: Carol McGee, Assistant Director, Office
of Derivatives Policy, Division of Trading and Markets, at (202) 551-
5870, Securities and Exchange Commission, 100 F Street NE., Washington,
DC 20549.
SUPPLEMENTARY INFORMATION:
I. Introduction
In the final rule further defining the term ``swap,'' the CFTC and
the SEC adopted an interpretation regarding the facts and circumstances
in which certain agreements, contracts, or transactions entered into by
commercial and non-profit entities should be considered not to be swaps
because they are customary commercial arrangements.\1\ Following
adoption of this interpretation, the CFTC received public comments
describing certain types of contracts that are closely tied to
regulatory obligations in the markets for electric power and natural
gas.\2\
---------------------------------------------------------------------------
\1\ See Further Definition of ``Swap,'' Security-Based Swap,''
and ``Security-Based Swap Agreement''; Mixed Swaps; Security-Based
Swap Agreement Recordkeeping, 77 FR 48207, 48246 (Aug. 13, 2012)
(the ``Products Release'').
\2\ The comments were received in response to the CFTC's
proposed interpretation on Forward Contracts With Embedded
Volumetric Optionality, 79 FR 69073 (Nov. 20, 2014) (comments
available at https://comments.cftc.gov/PublicComments/CommentList.aspx?id=1541), and the CFTC's notice of proposed
rulemaking on Trade Options, 80 FR 26200 (May 7, 2015) (comments
available at https://comments.cftc.gov/PublicComments/CommentList.aspx?id=1580). In addition, the CFTC's Energy and
Environmental Markets Advisory Committee discussed related issues at
its meeting on July 29, 2015 (transcript available at https://www.cftc.gov/PressRoom/Events/opaevent_eemac072915).
---------------------------------------------------------------------------
[[Page 20584]]
Having reviewed these comments, the CFTC proposes to issue guidance
regarding particular facts and specific circumstances in which these
contracts should be considered not to be ``swaps'' for purposes of the
Commodity Exchange Act (``CEA'').\3\ This proposed guidance applies the
interpretation in the Products Release to the contracts described in
Part II.A. of this document and the CFTC preliminarily concludes that
such contracts should be considered not to be swaps because they are
customary commercial arrangements.
---------------------------------------------------------------------------
\3\ See 7 U.S.C. 1a(47). This proposed guidance is being issued
jointly with the SEC pursuant to section 712(d)(4) of the Dodd-Frank
Act but, given the specific types of contracts at issue, pertains
only to the CFTC and swaps. Because the proposed guidance is limited
to the particular facts and circumstances of the contracts at issue,
the proposed guidance, if adopted, would not pertain to the SEC or
security-based swaps.
---------------------------------------------------------------------------
II. Proposed Guidance
A. Commenters' Description of Certain Contracts
Commenters described two types of contracts that are similar in
some respects, but are used in different situations to provide for
rights and obligations that are suitable to the parties' particular
needs in those situations, and which are closely tied to compliance
with certain regulatory requirements and frameworks. Each is described
briefly below.
1. Certain Capacity Contracts--Electric Power
The CFTC understands that certain types of capacity contracts in
electric power markets are used in situations where regulatory
requirements from a state public utility commission (``PUC'') obligate
load serving entities (``LSEs'') and load serving electric utilities in
that state to purchase ``capacity'' (sometimes referred to as
``resource adequacy'') \4\ from suppliers to secure grid management and
on-demand deliverability of power to consumers. A commenter explained
that the LSE or load serving electric utility will be recognized by the
PUC and the Federal Energy Regulatory Commission (``FERC'') as having
purchased capacity and, therefore, having satisfied that portion of its
obligation to purchase the ability to supply the electricity when and
as needed.\5\ In each of these instances, a commenter asserted, the
purchaser, as required by law, will be considered to have purchased the
supplier's capacity to generate, produce and deliver electric power,
regardless of whether the electricity underlying the capacity contract
is called upon and delivered.\6\
---------------------------------------------------------------------------
\4\ The resource adequacy framework adopted by the California
Public Utilities Commission (``CPUC'') is an illustrative example.
The CPUC adopted a resource adequacy policy framework in 2004 in
order to ensure the reliability of electric service in California.
The CPUC established resource adequacy obligations applicable to all
LSEs within the CPUC's jurisdiction. The CPUC's resource adequacy
policy framework--implemented as the Resource Adequacy program--
guides resource procurement and promotes infrastructure investment
by requiring that LSEs procure capacity so that capacity is
available to the California Independent System Operator (``ISO'')
when and where needed. See generally the discussion of resource
adequacy available at https://www.cpuc.ca.gov/ra/.
\5\ See letter from International Energy Credit Association
(``IECA'') (June 22, 2015) at 9. The CFTC understands that this type
of contract enables a Regional Transmission Organization (``RTO'')
or ISO to call on resource adequacy capacity to ensure the
reliability of electric service to end users or consumers. The LSE
or load serving electric utility, which is required to purchase
capacity contracts, cannot itself call on the supplier to deliver
electricity--only the RTO or ISO can.
\6\ See id.
---------------------------------------------------------------------------
A commenter said the purchaser does not treat this type of capacity
contract as a ``hedge'' in the same sense as it would otherwise use a
commodity option as a financial hedge.\7\ In this type of capacity
contract, the commenter contended, the purchaser is not procuring the
right to profit from a change in the value of the underlying commodity,
which the purchaser will then financially settle in order to offset the
price volatility risk of some underlying physical transaction in the
cash market.\8\ Rather, the purchaser is purchasing a supplier's
capacity to produce, generate, and deliver the underlying electricity,
thereby ensuring its ability to supply electricity in compliance with a
regulatory requirement.\9\ Certain commenters explained that they do
not view these contracts as financial instruments, but rather as
commercial agreements that enable the purchaser of capacity to ensure
that the underlying electricity is delivered when needed by the
purchaser to meet state- and/or federally-required reliability
objectives.\10\ One commenter stated that state PUCs and the FERC
generally do not treat a purchase of capacity in this context as a
purchase of a financial instrument or an option, but rather as a
purchase of the ability to ensure delivery of the underlying physical
commodity.\11\
---------------------------------------------------------------------------
\7\ See id.
\8\ See id.
\9\ One commenter contended that although this type of capacity
contract may not impose a binding obligation on the parties to make
and take delivery of a specific quantity of electricity, it does
impose a binding obligation on the parties to make and take delivery
of the capacity. See id. at 10.
\10\ See letter from IECA (June 22, 2015) at 10, and letter from
Coalition for Derivatives End-Users (``CDEU'') (Dec. 22, 2014) at 7-
8.
\11\ See letter from IECA (June 22, 2015) at 10.
---------------------------------------------------------------------------
A commenter explained how the payment structure under a capacity
contract for resource adequacy is different from the payment structure
under a financially-settled commodity option. According to this
commenter, capacity contracts do not involve payment of a nominal
option premium, followed by payment of the full market price of the
electric power if and when the ``option'' is exercised.\12\ Instead,
the initial payment under the capacity contract frequently recovers for
the seller the entire fixed cost of producing, generating, supplying or
transmitting the electric power.\13\
---------------------------------------------------------------------------
\12\ See id. at 11.
\13\ See id. Resource adequacy capacity is not tied to a
specific power price and the purchaser of capacity does not have
access to the energy tied to the capacity requirement. The capacity
purchased is essentially conferred or assigned to the RTO or ISO,
and these entities can call the capacity.
---------------------------------------------------------------------------
2. Certain Peaking Supply Contracts--Natural Gas
Commenters requested further guidance on whether certain natural
gas contracts, which commenters labeled as ``peaking supply
contracts,'' and which are entered into by electric utilities (with or
without a minimum gas delivery requirement) should be regulated as
swaps.\14\ The CFTC understands a peaking supply contract in this
context to be a contract that enables an electric utility to purchase
natural gas from another natural gas provider on those days when its
local natural gas distribution companies (``LDCs'') curtail its natural
gas transportation service. For example, one commenter, Linden,
explained that it procures sufficient natural gas and gas
transportation services to operate its cogeneration facility in the
ordinary course through natural gas service agreements with its
LDCs.\15\ Linden
[[Page 20585]]
explained that its natural gas service agreements require Linden to
take natural gas from the LDCs if they supply it. However, to ensure
that the LDCs are able to meet their regulatory commitments to
prioritize and serve residential demand for natural gas, the local
board of public utilities (``BPU'') requires that the service
agreements permit the LDCs to interrupt natural gas transportation
service to Linden during certain specified conditions.\16\ Due to the
LDCs' tariff-based commitments to serve residential natural gas demand,
the BPU will not allow the LDCs to provide a ``firmer'' category of
natural gas service to Linden.\17\ Because of the possibility of these
interruptions of transportation service, Linden uses peaking supply
contracts to ensure it has sufficient natural gas to operate its
cogeneration facility during the interruptions.\18\
---------------------------------------------------------------------------
\14\ See letter from American Gas Association (``AGA'') (Dec.
22, 2014) at 9-11, letter from AGA (June 22, 2015) at 2-5; and
letter from Cogen Technologies Linden Venture, L.P. (``Linden'')
(June 22, 2015) at 2-3. For purposes of this proposed guidance, the
term electric utility means ``all enterprises engaged in the
production and/or distribution of electricity for use by the public,
including investor-owned electric utility companies; cooperatively-
owned electric utilities; government-owned electric utilities
(municipal systems, federal agencies, state projects, and public
power districts).'' See Federal Energy Regulatory Commission (FERC)
Glossary, available at https://ferc.gov/resources/glossary.asp.
\15\ Linden is an exempt wholesale generator selling electric
power at market-based rates under the jurisdiction of the FERC, and
owns and operates a combined cycle natural gas-fired cogeneration
facility located in Linden, New Jersey. The electricity produced
from Linden's generator is sold, under a long-term power purchase
agreement, to Consolidated Edison Company, which then uses the power
to serve the electricity needs of consumers in New York City. Steam
from Linden's operation is sold, also under a long-term contract, to
the co-located Bayway Refinery, the largest refinery on the East
Coast, for its industrial processes. See letter from Linden (June
22, 2015) at 1-3.
\16\ See id.
\17\ See id.
\18\ See id.
---------------------------------------------------------------------------
Linden represented that, under its natural gas service agreements,
the LDCs determine when the conditions for interrupting Linden's
service are present, and Linden therefore has no control over such
conditions. Thus, Linden does not have discretion as to whether and
when an interruption of service as described above will occur.\19\
---------------------------------------------------------------------------
\19\ See id. at 3.
---------------------------------------------------------------------------
Linden explained that, under the terms of its natural gas service
agreements, Linden is required to take natural gas from the LDCs if
they supply it. There is no ability for financial settlement under
Linden's peaking supply contracts, and natural gas supplied under those
peaking supply contracts cannot be re-sold by Linden.\20\ Linden
represented that the price for natural gas in its peaking supply
contracts is based on the market cost of fuel at specified delivery
points, plus a specified adjustment depending on delivery point.\21\
Thus, since Linden could not use that natural gas for any purpose other
than to fuel its facility when an interruption of service occurs,
Linden represented that it is practically limited to exercising its
right to take delivery under its peaking supply contracts only in the
event of an interruption of service, and that it has no discretion as
to whether and when it will exercise the right to take delivery under
its natural gas peaking supply contracts.\22\
---------------------------------------------------------------------------
\20\ See letter from Linden (Dec. 22, 2014) at 6.
\21\ See letter from Linden (June 22, 2015) at 4, n. 12.
\22\ See id. at 3-4.
---------------------------------------------------------------------------
3. Common Characteristics Described by Commenters
As they have been described by commenters, the natural gas and
electric power contracts discussed above are all entered into by
commercial market participants, who contemplate physical settlement of
the transactions, in response to regulatory requirements, the need to
maintain reliable supplies, and practical considerations of storage or
transport.\23\ In each case, the particular commodities covered by the
contract are needed by at least one of the parties for the normal
operation of its business, and the specific identity of the
counterparty is an important consideration because of, for example,
concerns about reliability or the practicability of supply.\24\
---------------------------------------------------------------------------
\23\ See letter from CDEU (Dec. 22, 2014) at 7, letter from EDF
Trading North America, LLC (Dec. 22, 2014) at 13.
\24\ See letter from AGA (Dec. 22, 2014) at 9.
---------------------------------------------------------------------------
B. Products Release Discussion of Commercial Contracts
In the Products Release, the CFTC and the SEC (the ``Commissions'')
adopted an interpretation to assist commercial and non-profit entities
in understanding whether certain agreements, contracts, or transactions
that they enter into would or would not be regulated as swaps.\25\ To
that end, the Products Release listed several specific types of
commercial agreements, contracts, and transactions that involve
customary business arrangements (whether or not involving a for-profit
entity) that will not be considered swaps, including: Employment
contracts; sales, servicing, or distribution arrangements; certain
fixed or variable interest rate commercial loans or mortgages; and
certain agreements, contracts, or transactions related to business
combination transactions, real property, intellectual property, and
warehouse lending arrangements.\26\ The Commissions stated their intent
that this interpretation should ``allow commercial and non-profit
entities to continue to operate their businesses and operations without
significant disruption and provide that the swap . . . definition [is]
not read to include commercial and non-profit operations that
historically have not been considered to involve swaps.'' \27\
---------------------------------------------------------------------------
\25\ See Products Release, 77 FR at 48246.
\26\ See id., 77 FR at 48247.
\27\ See id.
---------------------------------------------------------------------------
The Commissions also explained that the list provided in the
Products Release was not intended to be exhaustive and that there may
be other, similar types of agreements, contracts, and transactions that
also should not be considered to be swaps.\28\ The Commissions said
that in determining whether similar types of agreements, contracts, and
transactions entered into by commercial entities should not be
considered swaps, they intend to consider the characteristics and
factors that are common to the commercial transactions listed in the
Products Release, which are:
---------------------------------------------------------------------------
\28\ See id.
---------------------------------------------------------------------------
They do not contain payment obligations, whether or not
contingent, that are severable from the agreement, contract, or
transaction;
They are not traded on an organized market or over-the-
counter; and . . .
In the case of commercial arrangements, they are entered
into:
--By commercial or non-profit entities as principals (or by their
agents) to serve an independent commercial, business, or non-profit
purpose, and
--Other than for speculative, hedging, or investment purposes.\29\
---------------------------------------------------------------------------
\29\ See id.
---------------------------------------------------------------------------
The Commissions concluded that in determining whether an agreement,
contract, or transaction not enumerated in the Products Release is a
swap, the agreement, contract, or transaction will be evaluated based
on its particular facts and circumstances,\30\ and the representative
characteristics and factors set out in the Products Release ``are not
intended to be a bright-line test for determining whether a particular
. . . commercial arrangement is a swap.'' \31\
---------------------------------------------------------------------------
\30\ See id., 77 FR at 48248.
\31\ See id., 77 FR at 48250.
---------------------------------------------------------------------------
In the Products Release, the CFTC also addressed certain capacity
contracts and peaking supply contracts in the context of the CFTC's
interpretation of when an agreement, contract, or transaction with
embedded volumetric optionality would be considered a forward
contract.\32\ The CFTC stated that depending on the relevant facts and
circumstances, capacity contracts and peaking supply contracts may
qualify as forward contracts with embedded volumetric optionality if
they met the elements of the CFTC's interpretation of that
provision.\33\ This remains the case; the CFTC does not intend that the
proposed
[[Page 20586]]
guidance herein would affect the interpretation of when an agreement,
contract, or transaction with embedded volumetric optionality would be
considered a forward contract.\34\
---------------------------------------------------------------------------
\32\ See id., 77 FR at 48238.
\33\ See id., 77 FR at 48240.
\34\ The CFTC has clarified this interpretation. See Forward
Contracts With Embedded Volumetric Optionality, 80 FR 28239 (May 18,
2015). In this clarification, the CFTC addressed certain retail
electric market demand-response programs, under which electric
utilities have the right to interrupt or curtail service to a
customer to support system reliability. See id., 80 FR at 28242,
citing letter from the National Rural Electric Cooperative
Association, the American Public Power Association, the Large Public
Power Association, and the Transmission Access Policy Study Group
(Oct. 12, 2012) at 9.
The CFTC clarified that since a key function of an electricity
system operator is to ensure grid reliability, demand response
agreements, even if not specifically mandated by a system operator,
may be properly characterized as the product of regulatory
requirements within the meaning of the seventh element of the CFTC's
interpretation regarding forward contracts with embedded volumetric
optionality. For the avoidance of doubt, the CFTC reiterates that
the proposed guidance herein would not affect this interpretation.
Also, the CFTC's interpretations regarding full requirements and
output contracts, as provided in the Products Release, would be
unaffected by the proposed guidance herein. See Products Release, 77
FR at 48239-40.
Furthermore, the CFTC does not intend that the proposed guidance
would supersede or modify a document issued by the CFTC's Office of
General Counsel--``Response to Frequently Asked Questions Regarding
Certain Physical Commercial Agreements for the Supply and
Consumption of Energy,'' available at https://www.cftc.gov/idc/groups/public/@newsroom/documents/file/leaselike_faq.pdf--which
continues to be the position of the CFTC's Office of General Counsel
on the issues discussed in that document.
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C. Proposed Guidance on Whether Certain Contracts Should Be Considered
To Be Swaps
In response to the comments, described above, which were provided
by market participants regarding certain capacity contracts for
electric power and certain peaking supply contracts for natural gas,
the CFTC has considered the specific facts and circumstances of these
contracts in light of the interpretation in the Products Release of
when a contract would be considered not to be a swap because it is a
customary commercial arrangement.
The CFTC understands, based on the commenters' descriptions, that
the contracts described in Part II.A. above are not traded on an
organized market or over-the-counter, and do not have severable payment
obligations. Thus, the CFTC preliminarily believes that the contracts
described in Part II.A. are consistent with the first two elements of
the interpretation in the Products Release.\35\
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\35\ See Products Release, 77 FR at 48247 (the contracts ``do
not contain payment obligations, whether or not contingent, that are
severable from the agreement, contract, or transaction; [and] . . .
are not traded on an organized market or over-the-counter'').
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The CFTC has also considered the contracts described in Part II.A.
in light of the statement in the Products Release that, in order not to
be considered swaps, the contracts should be entered into ``[b]y
commercial or non-profit entities as principals (or by their agents) to
serve an independent commercial, business, or non-profit purpose, and
[o]ther than for speculative, hedging, or investment purposes.'' \36\
In view of all the facts and circumstances of the contracts described
in Part II.A., the CFTC preliminarily believes that such contracts
would satisfy this element of the Products Release, and therefore
should be considered not to be swaps under the interpretation set forth
in the Products Release because they are customary commercial
arrangements of the type described in the Products Release.
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\36\ See id.
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The CFTC notes that commenters have represented that the contracts
described in Part II.A. are entered into in response to regulatory
requirements, the need to maintain reliable supplies, and practical
considerations of storage or transport which arise in the course of the
normal operation of at least one party's business. In this respect, the
CFTC preliminarily believes that the contracts described in Part II.A.
are similar to certain contracts--namely, sales, servicing and
distribution arrangements, and contracts for the purchase of equipment
or inventory--listed in the Products Release as commercial contracts
that will not be considered swaps.\37\ Also, in the Products Release
the Commissions addressed commenters' assertion that all commercial
merchandising transactions hedge an enterprise's commercial risks by
stating that a commercial arrangement undertaken for hedging purposes
may or may not be a swap depending on the particular facts and
circumstances of the arrangement.\38\
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\37\ See id.
\38\ See id., 77 FR at 48249.
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The CFTC observes that when an entity enters into a purchase
contract, it is assured of a supply of the equipment or inventory it
will need in the future. Similarly, a service contract assures the
availability of a needed service in the future. The contracts described
in Part II.A. are similar to the purchase and service contracts
enumerated in the Products Release because they appear to satisfy the
elements of commercial contracts, transactions or arrangements that are
not considered swaps, including that they are entered into by
commercial or non-profit entities to assure availability of a
commodity, not to hedge against risks arising from a future change in
price for the commodity or to serve a speculative or investment
purpose.
As stated in the Products Release, whether a particular commercial
arrangement is a swap depends on the particular facts and circumstances
of the arrangement.\39\ This proposed guidance would not apply to any
agreement, contract or transaction other than those described in Part
II.A., and would not preclude the CFTC from issuing further guidance
considering other commodity contracts under the interpretation in the
Products Release.
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\39\ See id., 77 FR at 48248.
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III. Request for Comment
The CFTC believes that it would benefit from public comment about
its proposed guidance, and therefore requests public comment on all
aspects of its proposed guidance set forth above, and on the following
questions:
1. Are there natural gas and electric power contracts that would
not qualify as trade options within the scope of CFTC regulation 32.3
but which would be covered by the proposed guidance? If so, should the
proposed guidance be limited so that it encompasses only contracts that
do qualify as trade options? Why or why not?
2. Does the proposed guidance provide sufficient clarity on whether
the specific types of natural gas and electric power contracts in
question should or should not be considered to be swaps? If not, how
should the guidance be revised to provide more clarity?
3. Are there other facts and circumstances that the CFTC should
consider in determining whether the contracts described in Part II.A.
are swaps? If so, what are these factors and how should they be
considered?
4. Are there contracts (other than those described in Part II.A.)
that are entered into by participants in the electric power and natural
gas markets and necessitated by, or closely tied to, compliance with
regulatory obligations or frameworks that are similar to those
described in Part II.A.?
5. Are there other types of commodity contracts, outside of the
electric power and natural gas markets, which are necessitated by, or
closely tied to, compliance with regulatory obligations or frameworks
that should be considered under the interpretation in the Products
Release? If so, please describe these contracts and the regulatory
obligations and frameworks to which they are closely tied.
6. Are there public interest considerations regarding the natural
gas
[[Page 20587]]
and electric power contracts in question that should be reflected in
the proposed guidance? If so, why and how?
7. Does the proposed guidance provide sufficient clarity that it
does not supersede or modify the CFTC OGC FAQ referenced in footnote
34? Is there any potential overlap between the proposed guidance and
the CFTC OGC FAQ that should be further clarified? If so, what elements
of the proposed guidance should be clarified to indicate that the
proposed guidance does not supersede or modify the CFTC OGC FAQ?
8. With respect to natural gas peaking contracts, are there natural
gas providers other than LDCs, such as Intrastate and Interstate
Natural Gas Pipelines (as those terms are defined by the Energy
Information Administration),\40\ which are subject to regulatory
obligations to prioritize and serve residential demand for natural gas,
such that the providers are obligated to curtail service to electric
utilities under certain circumstances? If so, please explain.
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\40\ See Distribution of Natural Gas: The Final Step in the
Transmission Process, Energy Information Administration, Office of
Oil and Gas, June 2008, available at https://www.eia.gov/pub/oil_gas/natural_gas/feature_articles/2008/ldc2008/ldc2008.pdf.
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By the Securities and Exchange Commission.
Dated: April 4, 2016.
Brent J. Fields,
Secretary.
Issued in Washington, DC, on April 4, 2016, by the Commodity
Futures Trading Commission.
Christopher J. Kirkpatrick,
Secretary of the Commission.
Commodity Futures Trading Commission (CFTC) Appendices to Certain
Natural Gas and Electric Power Contracts--Commission Voting Summary and
Chairman's Statement
Appendix 1--Commodity Futures Trading Commission Voting Summary
On this matter, Chairman Massad and Commissioners Bowen and
Giancarlo voted in the affirmative. No Commissioner voted in the
negative.
Appendix 2--Statement of CFTC Chairman Timothy G. Massad
Today, the CFTC and the Securities and Exchange Commission
(SEC), have jointly proposed guidance relating to the appropriate
treatment of certain peaking supply and capacity contracts. We are
issuing this guidance after considering the useful input we have
received from market participants expressing concern about this
issue. I support this proposal, as it will properly clarify the
treatment of contracts used by many businesses with respect to the
supply and delivery of electric power and natural gas.
We have proposed that certain electric power and natural gas
contracts should not be considered ``swaps'' under the Commodity
Exchange Act. We have done so because we believe they are examples
of customary commercial arrangements as described in the final rule
defining the term ``swap.''
For example, these contracts are entered into to assure
availability of a commodity, not to hedge against risks arising from
a future change in price of that commodity or for speculative, or
investment purposes. They are typically entered into in response to
regulatory requirements, the need to maintain reliable energy
supplies, and practical considerations of storage or transport. All
of these factors are consistent with what has been set forth in
previous commission guidance.
Today's proposed guidance is an important complement to our
final rule regarding Trade Options, which will reduce burdens on
end-users and allow them to better address commercial risk. I thank
my fellow Commissioners Bowen and Giancarlo for joining me in
unanimously approving this proposal as well as that final rule.
[FR Doc. 2016-08076 Filed 4-7-16; 8:45 am]
BILLING CODE 6351-01-P;8011-01-P