Position Limits Regulation - Comment Letter - Hess Corporation - March 28, 2011

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Position Limits for Derivatives
March 28, 2011

From the comment letter:

Hess believes that the Commission “should not treat the mere existence of a guaranty as a ‘proxy’ for trading control. Aggregating positions anytime a payment guaranty, lien, letter of credit, or other standard credit arrangement exists between two parties would be over-broad and inconsistent with the purposes that position limits were meant to serve.” They further argue that “consolidated financial statements do not demonstrate actual common control by the parent over the day-to-day trading decisions of its subsidiary. A rule that aggregates positions based on the accounting systems would, without more, be unnecessarily broad and an inefficient way to implement the intended purposes of position limits provision in the CEA.”

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