Thanks for forwarding the request for no-action letter.  I'll review it with 
Mark.

It seems that the suggested policy should not be problematic for us.  We 
would just want to make sure that nothing in the policy could be construed to 
prevent Enron from conducting the very activities that are contemplated by 
the Posting Agreement.  Since the only information we should be getting 
through our relationship with True Quote (absent a board seat) is information 
from potential EnronOnline counterparties hitting our prices (and it would be 
the same information, and no more, that we would be receiving if the party 
were dealing directly with EnronOnline), it seems unlikely that we could ever 
be in a position to violate a policy that True Quote would adopt.  Am I 
thinking about this correctly?


Travis McCullough
Enron North America Corp.
1400 Smith Street EB 3817
Houston Texas 77002
Phone:  (713) 853-1575
Fax: (713) 646-3490      



	"Joe Wright" <joe.wright@truequote.com>
	11/08/2000 09:38 AM
		 
		 To: <travis.mccullough@enron.com>
		 cc: "Chris Edmonds"@carvey.adgrafix.com, "Dennis Crum"@carvey.adgrafix.com, 
"Todd Creek"@carvey.adgrafix.com
		 Subject: Material Non-public Information and the CFTC


Travis,

On further review I believe there is no issue here.

True Quote must represent that persons who are 10% or more interest holders,
members of the Board of Directors or senior officers of TQ are not subject
to the statutory disqualifications from registration listed in the Commodity
Exchange Act.  You have indicated that in regard to Enron that TQ should be
able to make this representation.

However, we do not have to make a representation that the same persons will
not trade on or disclose material, non-public information.  Instead, all TQ
has to do in this regard is agree that it will endeavor to prevent and will
adopt a policy which prohibits any director, officer, employee or agent who
gains access to material, non-public information from trading for such
person's account or another account and from disclosing such information if
it would be inconsistent with that person's performance of his official
duties.   In order to comply with what the CFTC is requiring of us we would
simply agree to this and adopt such a policy.

Let me know what you think; but, I believe we are okay here.

Joe Wright
Enron Emails
Enron Emails