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Writer's pictureCharity Colleen Crouse

Regarding "Calculating Exposure Amount of Derivative Contracts" 1-Year Review Part II


In this review, a proper placement would consider the midstream factors and their role in the totality of the process. From this vantage point, consider "pooling" as related to terms, conditions and processes for "capture" that lack specificity around definition and distinction. Without appropriate disaggregation of intangible "costs" and "revenue" considerations and subsequent ascribement of appropriate valuations and access requirements, the "risk" for illicit activities to be considered as a justifiable or acceptable strategy increase. On the other hand, greater distinction, definition and specificity of intangible processes and contributions can create additional, potentially variegated, and more demonstrably and appropriately risk-calibrated value streams and options that can also be used and applied to create possibilities for monetization and/or assessments of accrued or actualized value.


This enables a more comprehensive and accessible model for discerning acceptable and unacceptable risk, reducing cost associated with the final product by acknowledging the products throughout the process per a disaggregated distinction, and appropriately addressing risk factors, including regulatory compliance, licensing, patent/copyright possibilities and responsibilities, as well as potential crime and liability. Certainly such processes would contribute a great deal to addressing long-standing factors concerning royalties and mineral rights claims as well.


This can then create and promote systemization of acquiring value based on meeting time-labor benchmarks, such as adherence to and passage of compliance reviews and inspections and value-added benchmarks for safety and economic progress of all of those associated with the process, which in turn assists with appropriate definition of potentially concurrent but necessarily distinguished and individualized protected streams. Consumption and decisions around consumption of the respective products would then have a greater chance for democratization and contribute to efforts to accrue meritorious value for conservation.


These matters should be considered in conjunction with information and recommendations provided in a public comment on Jan. 20, 2020 to the Commodity Futures Trading Commission regarding Information Collection 84 FR 63861. These can then be evaluated in consideration of long-standing concerns regarding subsidies that go back to the 1980s that were intended to assist the gas and oil sector with transitioning into other forms of energy production that until today have not been addressed comprehensively as well as the proliferation and association of the sector with retail outlets through efforts at diversification.


7:54 pm CST

March 14, 2020

Proofread and edited by 8:06 pm CST

Posted 8:10 pm CST

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