Position Limits Regulation - Comment Letter - Morgan Stanley - March 28, 2011

From MarketsReformWiki
Jump to: navigation, search

Position Limits for Derivatives
March 28, 2011

In their comment letter, Morgan Stanley suggests the Commission should:

  • defer consideration of position limits until after it has sufficient data about the size of the relevant markets and the positions held by market participants
  • define bona fide hedging transactions and positions more broadly to include long-standing and important risk management transactions, and retain a mechanism by which hedgers can obtain exemptions for non-enumerated hedging transactions
  • exercise its exemptive authority to establish a process by which liquidity providers can obtain exemptions from speculative position limits;
  • eliminate the limitation on holding a speculative position in a spot-month physical-delivery contract while holding a proposed conditional position in a spot-month cash-settled contract of up to five times the speculative limit
  • not condition, curtail or eliminate the availability of longstanding exemptions from the aggregation requirements based on the lack of control over trading.


MarketsReformWiki Sponsors

RSM US LLP ADM Investor Services Cinnober Fidessa