​NRECA and the American Public Power Association (APPA) submitted comments to the Commodity Futures Trading Commission (CFTC) on its Notice of Proposed Rulemaking for the De Minimis Exception to the Swap Dealer Definition. NRECA and APPA support the CFTC fixing $8 billion as the de minimis threshold for the level of swap dealing activity that would require an entity to register as a "swap dealer." The comments also support the CFTC's proposal to exclude from consideration as part of an entity's "swap dealing activity" those swaps that are entered into for the primary purpose of hedging. FULL FILING