Position Limits Regulation - Comment Letter - Deutsche Bank - March 28, 2011

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Position Limits for Derivatives
March 28, 2011

Deutsche Bank comments that:

  • Positions of affiliated entities that have independent trading strategies and decision making and have the proper procedures in place to wall off information should not be aggregated. The Commission should adopt rules that would permit a complex financial institution to disaggregate positions taken by its separately operated business units upon demonstrating that it employs policies, procedures, and physical barriers that separate management and flow of information.
  • Swap dealers' positions, entered into to hedge the dealers' exposure in the course of providing services to clients, should be exempt regardless of whether the client is a bona fide hedger or not
  • The presence of an intermediary in a chain transaction should not remove a swap dealer's ability to rely on the status of the initial bona fide hedger
  • The legacy position limits for agricultural commodities should be increased from proposed levels and based on a percentage of open interest.”


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