On October 27, the CFTC announced that it will hold an open meeting on November 3 to clarify: (i) when residual interest must be posted by futures merchants; (ii) record keeping requirements of commodity interest and related cash or forward transactions; and (iii) the  interpretation of when an agreement, contract, or transaction that contains embedded volumetric optionality falls outside the exception of being considered a swap. The November 3 meeting will be held at the CFTC headquarters in Washington, DC and will be available via webcast or conference call.