Position Limits Regulation - Comment Letter - Working Group of Commercial Energy Firms - March 28, 2011

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Dodd-Frank Timeline, Position Limits for Derivatives
Interim and Final Rule VACATED BY COURT ORDER Re-proposed Rule Issue Comment Deadline (reopen February 26, 2015)
November 18, 2011 September 28, 2012 November 5, 2013 March 28, 2015

Position Limits for Derivatives
March 28, 2011

The Working Group believes that if implemented “without sufficient study, speculative position limits will disrupt today’s highly efficient energy commodity markets by reducing liquidity, impairing price discovery, and preventing market participants from effectively and efficiently hedging their commercial risk exposure. The Working Group further states that “the Phase I spot-month position limits must be reconsidered in many respects and more appropriately accommodate the hedging needs of market participants. The process for determining deliverable supply must be fully transparent and provide market participants the opportunity to comment on the DCM estimates of deliverable supply and any Commission proposal for spot-month position limits.”

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