Position Limits Regulation - Comment Letter - Managed Funds Association - March 28, 2011

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Position Limits for Derivatives
March 28, 2011

MFA argues that:

  • The Commission’s proposed limits do not strike the right balance amongst the prescribed statutory goals of diminishing excessive speculation and deterring market manipulation, and ensuring sufficient market liquidity for bona fide hedgers and the price discovery function of the underlying market.
  • The Commission’s proposed changes to the disaggregation rules will result in unnecessary aggregation of independently controlled accounts, burden investors and investment managers, and potentially reduce liquidity in U.S. futures markets.
  • The Commission should restore the inter-commodity hedge and arbitrage exemptions that the Proposed Rules appear to have deleted, which are central to managing risk and maintaining balanced portfolios.

References

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