Position Limits Regulation - Comment Letter - Minneapolis Grain Exchange - December 2, 2010
|Final Rule||Effective Date||No-action Relief Deadline|
|July 22, 2011||September 20, 2011||June 30, 2013|
Position Reports for Physical Commodity Swaps
December 2, 2010
In the comment letter, MGEX shares five concerns regarding physical position reports for its hard red spring wheat (HRSW) contracts:
- "Disruption in pricing and activity in the HRSW contract could well occur should futures position limits among the wheat contracts vary."
- The commission is "acting before adequate information is known about the activity and volume of swaps."
- "Setting position limits aggregately across DCMs is begging for potential discrimination."
- Regarding the process for “pairing” a swap with a futures contract, "more clarity is necessary."
- A final concern is "the unknown financial risk and business risk the proposed rulemaking presents."