Excerpt:
The National Rural Electric Cooperative Association ("NRECA") and the American Public Power Association ("APPA", and collectively the not-for-profit or "NFP Electric Associations")1 respectively submit these comments in response to the Request for Comment contained in the Draft Technical Specifications for Certain Swap Data Elements (the "TechSpec Request"), issued by the staff (the "Staff") of the Commodity Futures Trading Commission (the "Commission" or "CFTC") on December 22, 2015. FULL FILING ​