Position Limits Regulation - Comment Letter - Futures Industry Association - January 17, 2012

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Position Limits for Derivatives
January 17, 2012

In their comment letter, the FIA explains that:

  • The Commission should withdraw the Position Limits Rule, including the interim spot-month position limits on cash-settled Referenced Contracts, until after it has collected and analyzed the data needed to make the statutorily required finding that:
    • Limits on cash-settled Referenced Contracts are “necessary” to “diminish, eliminate, or prevent” the burden on interstate commerce caused by excessive peculation; and
    • If limits are necessary, then the limit levels imposed by the Commission are “appropriate.”
  • If the Commission does not withdraw the interim spot-month position limits on cash-settled Referenced Contracts, then, at a minimum, it should the steps outlined in their comment letter to reduce the adverse effects of the Position Limits Rule
  • The Commission should amend the definition of “swaption” and clarify the definition of the spot-month for cash-settled Referenced Contracts

References

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