Position Limits Regulation - Comment Letter - Minneapolis Grain Exchange- March 30, 2015
Position Limits for Derivatives
March 5, 2012
From the comment letter:
"In general, MGEX supports the concerns raised by the various EEMAC members and presenters, especially with regard to the estimation of deliverable supply and the unsuitability of a one size fits all approach for spot month limits. Like the energy markets, deliverable supply in the agricultural markets is affected by numerous market factors, and MGEX therefore encourages the CFTC to give as much deference as possible to DCMs and allow them the necessary discretion to establish spot month limits. DCMs have been and remain in the best position to monitor deliverable supply and, if necessary, lower spot month limits in order to timely and quickly respond to market realities."
"Despite increasing market participation in HRSW and HRSW’s status as the largest wheat class crop in North America, the Proposed Rule sets a single month and all months combined limit for MGEX HRSW at 3,300—a staggering 72.5% decrease from its current limit of 12,000 contracts."