Position Limits Regulation - Comment Letter - Coalition of Physical Energy Firms - March 28, 2011

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Position Limits for Derivatives
March 28, 2011

From the comment letter:

“COPE requests that the Commission not move forward with a final position limits rule. The Position Limits NOPR is not supported by empirical evidence and will impose a significant compliance burden on traders, their compliance personnel, and regulators alike. The Commission's already significant burden of market surveillance and enforcement, as increased by mandatory Dodd-Frank rulemakings, will only be further strained by unnecessary imposition of discretionary position limits that will prove as difficult to enforce as they will be to comply with. Rather than continue to pursue a position limits rule, the Commission should focus its resources on the mandatory aspects of Dodd-Frank and not burden itself and market participants with additional and questionable compliance obligations.”


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