Position Limits Regulation - Comment Letter - Working Group of Commercial Energy Firms - January 17, 2012

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Position Limits for Derivatives
January 17, 2012

In their comment letter, the Working Group expresses their support for “appropriate regulation that brings transparency and stability to the swap markets.” More specifically, they write that:

  • The Commission should study and identify the size of cash markets for referenced contracts in energy commodities to avoid setting overly restrictive spot-month position limits
  • They support spot-month class limits for physically-delivered and cash-settled referenced contracts in energy commodities at a level no less than a 1:5 ratio
  • The 1:5 ratio for spot-month limits for cash-settled contracts has existed without causing disruption in certain energy markets


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