Position Limits Regulation - Comment Letter - ISDA - March 30, 2015

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Position Limits for Derivatives
March 5, 2012'

From the comment letter:

"It is our position that the Commission should not go forward with the Proposal until such time as it is able to demonstrate that the statutory prerequisites to imposing position limits have been satisfied and until such time as the Commission has meaningfully evaluated the costs and benefits of the rules it intends to impose."

"Should the Commission determine to go forward with the Proposal, the Commission should, among other things, abandon those aspects of the Proposal that would impose position limits outside of the spot month. As an alternative to those limits, the Commission should use its existing tools—surveillance capabilities, special call authority, and oversight authority of designated contract markets and swap execution facilities—to address concerns related to excessive speculation outside of the spot month."


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