Please give me your views ASAP.
Thanks for the language.  We will make sure that weather derivatives are
included.  We met with the CFTC yesterday and they oppose excluding energies
from the Act.  Our bill would require that these excluded products, if traded 
on
an electronic trading system, to be subject to the antimanipulation authority 
of
the CFTC and not allow these products to require delivery.  One issue they
raised was price discovery and that these markets are not very transparent. 
What would be your reaction if we added a third provision (again this is only
for energies traded on a electronic trading facility--bilateral transactions
would not be subject to these provisions) that required some sort of price
disclosure for these markets.  That might help placate the CFTC, but I'm not
sure what the industry reaction might be.  Let me know.

____________________Reply Separator____________________
Subject:    Energy Language
Author: RAISLERK@sullcrom.com
Date:       5/2/00 10:32 AM

Attached is a revised Section 1a(13).  The new language is underlined.  I
suggest that we retain Section (B).  It seems to me to be helpful and captures
products such as weather derivatives.  I have bracketed the manipulation
language as a place-holder consistent with our discussions.  Please let me 
know
if you think these revisions work.


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 - Excluded Commodity Language.doc