Position Limits Regulation - Comment Letter - CME Group - October 25, 2010

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Pre-Rulemaking Position Limit Comments
October 25, 2010

From the letter:

"Our comments regarding the Commission's § 4a position limit authority will focus on: 1) the statutory requirements for the Commission's establishment of position limits, and 2) the features the Commission should adopt for any necessary position limit regime (e.g., timing, exemptions, and aggregation standards). In offering these comments, CME Group has been cognizant of the extensive demands that are being made on the Commission‟s limited resources. However, the Commission must gather critical data regarding swap markets and individual traders‟ swap positions. Without a thorough understanding of such data, the Commission runs the risk of inappropriately setting position limits. CME Group appreciates the great challenge this presents to the Commission and suggests in this letter ways to reduce the strain on the Commission‟s resources while still serving our mutual goal of effective market surveillance to deter price manipulation and other abusive practices."

Articles on CME Position Limit Comment Letter

On October 28, 2010, Reuters reported that "The U.S futures regulator risks harming commodity markets with overly restrictive speculative trading limits, CME Group Inc and Morgan Stanley (Berlin: SYC.BE - news) each told the Commodity Futures Trading Commission in letters released on Wednesday. The comment letters come as the CFTC prepares to unveil a new position limits plan in coming weeks, part of its mandate under the new Wall Street reform law, and a top concern for commodities traders."[1]


  1. UPDATE 2-Morgan Stanley, CME pan CFTC position limits. Reuters. Retrieved on December 8, 2010.

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