Excerpt:

The National Rural Electric Cooperative Association (“NRECA”) and the American Public Power Association (“APPA”) (collectively referred to as the not-for-profit or “NFP Electric Associations,” whose members are customer-owned electric utilities), welcome the Commodity Futures Trading Commission (“CFTC” or “Commission”)’s “Project KISS” review of its rules, regulations, and practices to identify areas where the CFTC’s requirements can be applied in a simpler, less burdensome and less costly manner. The NFP Electric Associations respectfully submit these comments and recommendations on the Project KISS topic of “Reporting.”

Project KISS (Reporting)

Project KISS (Misc)