​Excerpt:

The National Rural Electric Cooperative Association (“NRECA”)1 respectfully submits these comments in response to the notice2 issued by the Commodity Futures Trading Commission (“CFTC” or “Commission”) that it intends to renew data collection activities for the Ownership and Control Reporting rules (the “OCR Rules”), including Forms 40/40S as initiated via “special call” by the Commission staff.

NRECA has been an active participant in the Commission’s numerous rulemakings implementing the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).3 In particular, NRECA filed comments (the “2012 Comments”) together with certain other electric industry trade associations (the “Joint Electric Associations”) in the rulemaking related to post-Dodd Frank Act amendments to the OCR Rules to include reporting of nonfinancial commodity swaps (the “OCR Rule Amendments for Swaps”).⁴  FULL FILING