On February 7, 2011, Financial Executives International (FEI) joined the Coalition for Derivatives End-Users in sending a comment letter to the U.S. Commodity Futures Trading Commission (CFTC) on their proposed rule RIN number 3038–AD08, Real-Time Public Reporting of Swap Transaction Data, 17 CFR Part 43.  Specifically, the letter expresses concerns that end-user affiliates could be swept up in reporting requirements; that implementing a maximum time delay may be problematic for entities that do not have the resources to report in short order; and reaffirms the need to exempt foreign exchange swaps and forwards from the scope of the rules.