Position Limits Regulation - Comment Letter - ISDA & SIFMA - January 17, 2012

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Position Limits for Derivatives
January 17, 2012

From the comment letter:

“We believe the Commission should withdraw 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, and should then adopt any such limits only to the extent that it finds, upon a complete examination of that data, that:

  1. excessive speculation exists in the markets for cash-settled Referenced Contracts,
  2. limits on cash-settled Referenced Contracts are “necessary” to “diminish, eliminate, or prevent” the burden on interstate commerce caused by that excessive speculation, and
  3. the imposition of position limits and levels of the limits imposed by the Commission are “appropriate.”


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