RE:

Enron was part of a consortium of energy trading companies known as the Energy Group (this included Goldmann Sachs, Morgan Stanley, BP America, Enron,Koch Industries, Mobil Business, Phibro, and Sempra). The Energy Group was managed by Sullivan Cromwell in NY - contact is Ken Raisler at (212) 558-4675. We also worked with the International Swaps and Derivatives Association (ISDA). The Energy consortium and ISDA worked with Congress to bring legal certainty to the OTC derivatives market, including those transactions completed on a electronic trading facility, during the debate on the Commodities Futures Modernization Act (CFMA) which became law earlier this year. We were simply one of many parties that asked Congress to swiftly move to eliminate legal uncertainty over OTC derivative transactions and reduce the regulatory burden placed on sophisticated market participants.

In the end, bilateral trading facilities (like Enron) were exempted from the Commodity Exchange Act. However, Enron Online is not without any oversight. The CFTC retained antifraud and antimanipulation authority over transactions completed on Enron OnLine and the Department of Justice and FTC can review these facilities.

In the Spring, we answered questions from FERC about EnronOnLine and had several FERC staff to Houston to better understand the EnronOnline, but this could hardly be called lobbying.

You may want to take a look at the Q&A document produced by Lisa Yoho for more information.

Feel free to call me at home over the weekend. Cell is (202) 253-2524 or home (703) 721-2036.

-----Original Message-----
From: Steffes, James D.
Sent: Friday, October 26, 2001 4:01 PM
To: Long, Chris; Novosel, Sarah
Subject:

What lobbying did Enron do last year with regard to EnronOnline and the Commodity Futures Modernization Act?