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

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Position Limits for Derivatives
March 28, 2011

From the comment letter:

“Cargill's business will be significantly affected by the Proposed Rules. The hedge exemption is vital to Cargill's management of its commodity price risk in its business activities as a purchaser, processor and seller of physical commodities. In tum, Cargill's ability to manage its own risk impacts the prices it pays to agricultural producers who supply commodities to Cargill, as well as the prices it charges to processors and end-users who buy from Cargill. Position limits and the hedge exemption are also important for Cargill's business of providing risk management services to other businesses, by acting as a swap counterparty to businesses using swaps to hedge their risks.”


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