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WSPP Voluntary Dodd-Frank Act Listing
Self Designations


WSPP has received the following self-designations from WSPP members:

Swap Dealer
Major Swap Participant
Special Entity
End User
City of Riverside No No Yes Yes 549300FG48YQF1N4C302
CP Energy Marketing (US) Inc. No No No Yes L0S449PGNYVSUYA1CI33
City of Pasadena No No Yes Yes 5493007ZF3ZMBUWLWB58
Arizona Public Service Company No No No Yes YG6VT0TPHRH4TFVAQV64
EWEB No No Yes Yes 549300P1P01XKFQ38R71
Exelon Generation Company, LLC No No No Yes S2PEWKCZFFECR4533P43
Grant County PUD No No Yes Yes 549300XJXH7RNXS8PA58
J.P. Morgan Ventures Energy Corporation Yes No No No CY7NSF4GMU5SQHINWC28
Modesto Irrigation District No No Yes Yes S6U6XLZ7IOWYIG8C8H50
Portland General Electric No No No Yes JOUP9M7C39GLSK9R870
Puget Sound Energy, Inc. No No No Yes 8MNFJR7KOMBQ7X62LK44
Safeway Inc. No No No Yes 549300NKZ6VCN5P3K723
Sempra Generation No No No Yes O272EHCTP7Q5Z8STG197
Tacoma Power No No Yes Yes 5493007ZRQFFKMZS5634
Tenaska Power Services Co. No No No Yes 549300K7NFSB93YGBN35
The Energy Authority, Inc. No No No Yes 1GCHJLKRFMUYSJOP4C27
Union Power Partners, L.P. No No No Yes 549300SFPQG04OTQXB65
Enmax Energy Corporation No No No Yes 5493003P7OH76BCOGR08
Enmax Energy Marketing Inc. No No No Yes 549300XAE5VP5ONZTO34
TransAlta Energy Marketing (U.S.) Inc. No No No No AXDGVRS221XSIKGQXQ16
El Paso Electric Company No No No Yes 0Z8GM8L4AHPKSWZMW205



The Dodd-Frank Act amendments to the Commodity Exchange Act establish various certain designations which may apply to respective market participants. The designations include Swap Dealer, Major Swap Participant, and Special Entity. Also, some entities may be End Users, subject to the End User exemption. Information regarding these categories is provided below.
It is helpful for market participants to know if and how other participants designate themselves or whether they consider themselves End Users. For the convenience of WSPP members, WSPP provides the following listing of WSPP member self-designations. Participation in this listing is entirely voluntarily. Only those WSPP members who have provided listing information to WSPP are included. Omission does not imply any particular status or lack of status. Be advised that certain entities may be required to register their status with the National Futures Association.

A WSPP member may request listing through its Executive Committee or Operating Committee representatives or alternates, by email to the WSPP Operating Agent. A member’s name on the list must correspond to its name on the WSPP list of members at


WSPP will make diligent efforts to accurately set out the information a member provides. Each listed member shall be solely responsible for assuring and verifying the accuracy of its listing. Each member submitting information for this list WAIVES ANY CLAIMS IT MAY HAVE AT ANY TIME arising from any inaccurate listing.

The list and information it contains is based solely on the information the listed entities provide to WSPP. WSPP has not authenticated or conducted any due diligence investigation concerning the accuracy of any listing. WSPP EXPRESSLY DISCLAIMS ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED, concerning the accuracy of any member’s designation. No action by any WSPP representative shall be construed as a waiver by WSPP of the foregoing disclaimer. Further, the summary information set forth after the list regarding the meaning of the various Dodd-Frank designations is not legal advice. Participants using this list are advised to seek advice from their legal counsel regarding the meaning or use of the information and any associated legal obligations.


Swap Dealer (17 C.F.R. § 1.3(ggg)) - Any person who:

  • Holds itself out as a dealer in swaps,
  • Makes a market in swaps,
  • Regularly enters into swaps with counterparties as an ordinary course of business for its own account, or
  • Engages in activity causing itself to be commonly known in the trade as a dealer or market maker in swaps.
    - De minimis exception - The Dodd-Frank Act provides an exemption for a person who engages in a de minimis level of swap dealing activity. The de minimis level is calculated on the aggregate gross notional value of the swaps entered into starting October 20, 2012 for a rolling twelve months and does not exceed $8 billion. This de minimis level may decrease to $3 billion within five years. The exception threshold for swaps with “special entities” is a much lower $800 million gross notional value. Additionally, certain activity where swaps are used to hedge or mitigate risk will be excluded for purposes of calculating gross notional swap exposure. See 17 C.F.R. § 1.3(ggg)(4).

Major Swap Participant (17 C.F.R. § 1.3(hhh)) – a non-swap dealer that satisfies one of the following criteria:

  • A person that maintains a “substantial position,” as defined in 17 C.F.R. § 1.3(jjj), in any of the major swap categories (rate swaps, credit swaps, equity swaps and any other commodity swaps, see 17 C.F.R. § 1.3(iii)), excluding positions held for “hedging or mitigating commercial risk,” as defined in 17 C.F.R. § 1.3(kkk), and positions maintained by certain employee benefit plans for hedging or mitigating risks in the operation of the plan;
  • A person whose outstanding swaps create “substantial counterparty exposure,” as defined in 17 C.F.R. § 1.3(lll), that could have serious adverse effects on the financial stability of the United States banking system or financial markets; or
  • Any financial entity, that maintains a “substantial position” in any of the major swap categories, that is highly leveraged to the amount of capital such entity holds and that is not subject to capital requirements established by a federal banking regulator. For an entity to be deemed “highly leveraged,” as defined in 17 C.F.R. § 1.3(mmm), the Final Entity Rules adopt a ratio of total liabilities to equity of 12 to 1, as determined in accordance with U.S. Generally Accepted Accounting Principles.

Special Entity (17 C.F.R. § 23.401(c))

  • Federal agency;
  • A State, State agency, city, county, municipality, other political subdivision of a State, or any instrumentality, department, or a corporation of or established by a State or political subdivision of a State;
  • Any employee benefit plan subject to Title I of the Employee Retirement Income Security Act of 1974 (29 U.S.C.1002);
  • Any governmental plan, as defined in Section 3 of the Employee Retirement Income Security Act of 1974 (29 U.S.C.1002);
  • Any endowment, including an endowment that is an organization described in Section 501(c)(3) of the Internal Revenue Code of 1986 (26 U.S.C. 501(c)(3)); or
  • Any employee benefit plan defined in Section 3 of the Employee Retirement Income Security Act of 1974 (29 U.S.C. 1002), not otherwise defined as a Special Entity, that elects to be a Special Entity by notifying a swap dealer or major swap participant of its election prior to entering into a swap with the particular swap dealer or major swap participant

End User – (Non-Swap Dealer, Non-Major Swap Participant – Also referred to as an “End User” or “Other”.)

  • Note: This is not a designation of an entity type under Dodd-Frank.
  • The End-User Exception permits eligible counterparties to exclude qualifying swaps from the Clearing Requirement. See 17 C.F.R. § 39.6.

Legal Entity Identifier (LEI) /CFTC Interim Compliant Identifier (CICI) (17 C.F.R. § 45.6)

  • The legal entity identifier for each swap counterparty issued pursuant to section 45.6 of the CFTC’s regulations
  • The legal entity identifier will be a CICI until establishment of the global LEI system


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