Position Limits Regulation - Comment Letter - Futures Industry Association - December 2, 2010

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Timeline, Position Reports for Physical Commodity Swaps
Final Rule Effective Date No-action Relief Deadline
July 22, 2011 September 20, 2011 June 30, 2013

Position Reports for Physical Commodity Swaps
December 2, 2010

From the comment letter:

  • The commission is proposing to develop its report system "before it has had time to define what must be reported and precisely who must report, and before market participants have had an opportunity to build the infrastructure necessary to collect and protect the confidentiality of the required information."
  • "The burden of implementing the proposed transitional rule will greatly exceed the benefits to the commission and market participants."
  • "The reporting requirements under the proposed position reports rule are too broad."

The FIA letter concludes with a request for the implementation of a "modified special call" process during the transition.

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