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The Edison Electric Institute (“EEI”) and the National Rural Electric Cooperative Association (“NRECA”) (hereafter “Joint Associations”) respectfully submit these comments in response to the Proposed Rule on Recordkeeping issued by the Commodity Futures Trading Commission (“CFTC” or “Commission”).¹

EEI is the association of U.S. investor-owned electric companies. EEI’s members comprise approximately 70 percent of the U.S. electric power industry, provide electricity for 220 million Americans, operate in all 50 states and the District of Columbia, and directly employ more than 500,000 workers. With more than $100 billion in annual capital expenditures, the electric power industry is responsible for one million jobs related to the generation and delivery of power. FULL FILING