Position Limits Regulation - Comment Letter - ISDA and SIFMA - March 28, 2011

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Position Limits for Derivatives
March 28, 2011

ISDA and SIFMA argue that “the imposition of position limits of any kind are not supported by the legally required analysis of necessity and appropriateness. Thus, we recommend against the adoption of any limits until such an analysis establishes a legal basis for limits. Furthermore, we urge the Commission to refrain from imposing position limits unless and until its foreign counterparts impose comparable position limits on non-U.S. commodity markets, as raised by Dodd-Frank. If the Commission does adopt the Proposed Rules, we believe that substantial changes should be made to the proposed position limit regime to achieve the Commission’s objectives without unnecessarily disrupting or limiting the commodity markets.”

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