Position Limits Regulation - Comment Letter - Minneapolis Grain Exchange - March 28, 2011

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Position Limits for Derivatives
March 28, 2011

In their comment letter, MGEX recommends:

  • that any reporting entity granted an exemption should only need to file one report with a single entity. Since the Commission is that primary entity for processing and monitoring bona fide hedge exemptions, that information should be readily available to the CFTC and shared with the necessary DCM(s).
  • that there should be an exemption or exception from the proposed spot and non-spot position limits for new or illiquid futures contracts.
  • that that the non-spot position limits be kept consistent across the wheat contracts
  • the continued use of current spot month position limits for the three enumerated wheat contracts.


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