Very good question - while you don't need to worry about otc swaps, otc 
options might be a problem.  However, if the customer is not a US entity, the 
advice is all given outside the US and does not relate to US futures or 
options, we feel reasonably comfortable that the risk is quite low that there 
would be a problem.




Martin Rosell
06/24/99 10:08 AM
To: Mark - ECT Legal Taylor/HOU/ECT@ECT
cc:  
Subject: Re: Commodity Trading Advisor

Thanks for the response.  Does the term "futures contract" also include 
bilateral swaps (or it restricted to exchange-traded futures) and will it 
make any difference if the couterparty/customer is a non-US entity?!

Martin
---------------------- Forwarded by Martin Rosell/OSL/ECT on 24/06/99 16:06 
---------------------------


Mark - ECT Legal Taylor
24/06/99 16:53
To: Martin Rosell/OSL/ECT@ECT
cc:  
Subject: Re: Commodity Trading Advisor  

I think the answers will be the same for Stockholm - i.e. as long as we are 
not giving advice with respect to futures contracts (valuations or trading 
advice) or handling customer funds there should not be any Commodity Exchange 
Act issues.



Martin Rosell
06/14/99 09:08 AM
To: Mark - ECT Legal Taylor/HOU/ECT@ECT
cc:  
Subject: Commodity Trading Advisor

Mark, the business people posted at ECTRIC's office in Stockholm want to 
offer a Swedish forestry group portfolio management services and advisory 
services.  With reference to our previous conversations on the subject below, 
do you think that this may entail problems under US securities laws?!

Martin
---------------------- Forwarded by Martin Rosell/OSL/ECT on 14/06/99 15:05 
---------------------------


Martin Rosell
28/04/99 16:05
To: Mark - ECT Legal Taylor/HOU/ECT@ECT
cc:  
Subject: Commodity Trading Advisor

Mark:

Did you have any luck with your New York law firm contact.   The other party 
has accepted the contents of the contract and wish to sign on Tuesday next 
week, why it's a bit urgent to flag any US securities law implications 
associated with the relevant transaction.

Martin