Position Limits Regulation - Comment Letter - BlackRock - March 28, 2011

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Position Limits for Derivatives
March 28, 2011

From the comment letter:

BlackRock believes that “the Commission’s proposed rescission of its independent account controller approach to position aggregation and its replacement with a flawed alternative, would have major adverse impacts on our asset management business without any corresponding public benefits. Position holders and owners, as well as asset and fund managers that have authorized professional advisors to control their trading can not affect market prices and should not be subject to aggregation. If the Commission decides that federal position limits are necessary and appropriate at all, we strongly urge the Commission to reconsider its aggregation proposal and to return to its traditional policy of focusing on who controls trading.”

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