Position Limits Regulation - Comment Letters

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Gavel.png FINAL RULE: Position Limits for Futures and Swaps approved at October 18, 2011 open meeting
Dodd-Frank Timeline, Position Limits for Derivatives
Interim and Final Rule VACATED BY COURT ORDER Re-proposed Rule Issue Comment Deadline (reopen December 4, 2014)
November 18, 2011 September 28, 2012 November 5, 2013 January 22, 2015
Timeline, Position Reports for Physical Commodity Swaps
Final Rule Effective Date No-action Relief Deadline
July 22, 2011 September 20, 2011 June 30, 2013

The Commodity Futures Trading Commission (CFTC) asked for comment letters on the proposed Position Limits Regulations, which were mandated by the Dodd-Frank Act. The position limit rules were originally expected to be finalized by January 2011.[1] However, the commission tabled the position limits proposal until the CFTC Open Meeting, January 13, 2011.

The final rule on position limits was approved on October 18, 2011. After the issuance of the final rule, the commission reopened the comment period until January 17, 2012. These letters appear first.

Prior to its proposed rule on position limits, at its October 19, 2010 Open Meeting, the commission approved a proposal to establish a framework for the collection of position reports for physical commodity swaps. Comment letters addressing the physical commodity swaps position reports proposal can be found at the bottom of this page.

Members of the U.S. Congress - March 5, 2012

Position Limits for Derivatives
March 5, 2012

From the comment letter:

"As the cost for American people to fill their gas tanks continues to skyrocket, the CFTC continues to drag its feet on imposing strict speculation limits to eliminate, prevent, or diminish excessive oil speculation as required by the Dodd-Frank Act. Although the CFTC has adopted initial position limits, they are not strong enough and not yet in force owing to industry opposition, delays in swaps oversight and data collection. This is simply unacceptable and must change."

"We have a responsibility to ensure that the price of oil is no longer allowed to be driven up by the same Wall Street speculators who caused the devastating recession that working families are now experiencing. That means that the CFTC must do what the law mandates and end excessive oil speculation once and for all."

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ISDA & SIFMA - January 17, 2012

Position Limits for Derivatives
January 17, 2012

From the comment letter:

“We believe the Commission should withdraw the interim spot-month position limits on cash-settled Referenced Contracts until after it has collected and analyzed the data needed to make the statutorily required finding, and should then adopt any such limits only to the extent that it finds, upon a complete examination of that data, that:

  1. excessive speculation exists in the markets for cash-settled Referenced Contracts,
  2. limits on cash-settled Referenced Contracts are “necessary” to “diminish, eliminate, or prevent” the burden on interstate commerce caused by that excessive speculation, and
  3. the imposition of position limits and levels of the limits imposed by the Commission are “appropriate.”
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Intercontinental Exchange - January 17, 2012

Position Limits for Derivatives
January 17, 2012

From the comment letter:

“In the final rule, the Commission should retain the five to one limit for natural gas contracts. In addition, given the benefits of the Conditional Limit, the Commission should reconsider expanding the five to one limit to other commodities as considered in the proposed position limit rule.”

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Futures Industry Association - January 17, 2012

Position Limits for Derivatives
January 17, 2012

In their comment letter, the FIA explains that:

  • The Commission should withdraw the Position Limits Rule, including the interim spot-month position limits on cash-settled Referenced Contracts, until after it has collected and analyzed the data needed to make the statutorily required finding that:
    • Limits on cash-settled Referenced Contracts are “necessary” to “diminish, eliminate, or prevent” the burden on interstate commerce caused by excessive peculation; and
    • If limits are necessary, then the limit levels imposed by the Commission are “appropriate.”
  • If the Commission does not withdraw the interim spot-month position limits on cash-settled Referenced Contracts, then, at a minimum, it should the steps outlined in their comment letter to reduce the adverse effects of the Position Limits Rule
  • The Commission should amend the definition of “swaption” and clarify the definition of the spot-month for cash-settled Referenced Contracts
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CME Group - January 17, 2012

Position Limits for Derivatives
January 17, 2012

From the comment letter:

“A policy of higher spot-month limits for cash-settled contracts in any linked market is contrary to the longstanding joint policy of the Commission and the exchanges. Indeed, as the Commission notes in the Release, the Commission staff has historically deemed acceptable both for physical-delivery contracts and their cash-settled look-a-likes a spot-month limit of 25% of estimated deliverable supply. This is sound regulatory policy because for such linked contracts, any impact to physical supply is immediately translated to the physical contract settlement price by the laws of supply and demand, and necessarily to the settlement price of the cash-settled look-a-like given that it is settled to the physically-delivered contract. Similarly, activity in the cash settled linked market is immediately translated in the underlying core physically settled market.”

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Working Group of Commercial Energy Firms - January 17, 2012

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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Futures Industry Association - March 25, 2011

Position Limits for Derivatives
March 25, 2011

The FIA suggests that "spot month position limits for Referenced Contracts should not be based solely on 25 percent of 'the quantity of the commodity meeting a derivative contract’s delivery specifications.' Rather, the Commission should take into account 'the individual characteristics' of each core referenced contract, including the different settlement options — such as EFPs — available for each contract, in setting spot month position limits." FIA further states that the Commission should:

  • define bona fide hedging transactions and positions more broadly so that they encompass long-standing and important commercial risk management practices
  • re-institute a process by which hedgers can seek exemptions for non-enumerated hedging transactions
  • exercise its exemptive authority to implement a process by which liquidity providers can obtain hedge exemptions from speculative position limits.
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Managed Funds Association - March 28, 2011

Position Limits for Derivatives
March 28, 2011

MFA argues that:

  • The Commission’s proposed limits do not strike the right balance amongst the prescribed statutory goals of diminishing excessive speculation and deterring market manipulation, and ensuring sufficient market liquidity for bona fide hedgers and the price discovery function of the underlying market.
  • The Commission’s proposed changes to the disaggregation rules will result in unnecessary aggregation of independently controlled accounts, burden investors and investment managers, and potentially reduce liquidity in U.S. futures markets.
  • The Commission should restore the inter-commodity hedge and arbitrage exemptions that the Proposed Rules appear to have deleted, which are central to managing risk and maintaining balanced portfolios.
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ISDA and SIFMA - March 28, 2011

Position Limits for Derivatives
March 28, 2011

ISDA and SIFMA argue that “the imposition of position limits of any kind are not supported by the legally required analysis of necessity and appropriateness. Thus, we recommend against the adoption of any limits until such an analysis establishes a legal basis for limits. Furthermore, we urge the Commission to refrain from imposing position limits unless and until its foreign counterparts impose comparable position limits on non-U.S. commodity markets, as raised by Dodd-Frank. If the Commission does adopt the Proposed Rules, we believe that substantial changes should be made to the proposed position limit regime to achieve the Commission’s objectives without unnecessarily disrupting or limiting the commodity markets.”

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Goldman Sachs - March 28, 2011

Position Limits for Derivatives
March 28, 2011

Goldman Sachs offers their concerns about the Proposed Rules, stating that “the manner in which the Proposed Rules would apply limits to positions that are ‘concentrated’ when viewed in the unduly narrow context of belonging to a swap or futures ‘class,’ without giving effect to offsets across classes, will reduce liquidity for bonafide hedgers and will impair the price discovery process… Accordingly, it is our view that the costs and potentially disruptive effects of the Proposed Rules outweigh their potential benefits. If the Commission determines that it is necessary to impose position limits, we respectfully urge that it modify its approach by applying limits exclusively to spot month positions in contracts that may be physically-settled. To the extent that the Commission imposes limits on both futures and swaps, we recommend that it recognize offsets between such positions.”

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Morgan Stanley - March 28, 2011

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.
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Deutsche Bank - March 28, 2011

Position Limits for Derivatives
March 28, 2011

Deutsche Bank comments that:

  • Positions of affiliated entities that have independent trading strategies and decision making and have the proper procedures in place to wall off information should not be aggregated. The Commission should adopt rules that would permit a complex financial institution to disaggregate positions taken by its separately operated business units upon demonstrating that it employs policies, procedures, and physical barriers that separate management and flow of information.
  • Swap dealers' positions, entered into to hedge the dealers' exposure in the course of providing services to clients, should be exempt regardless of whether the client is a bona fide hedger or not
  • The presence of an intermediary in a chain transaction should not remove a swap dealer's ability to rely on the status of the initial bona fide hedger
  • The legacy position limits for agricultural commodities should be increased from proposed levels and based on a percentage of open interest.”
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CME Group- March 28, 2011

Position Limits for Derivatives
March 28, 2011

CME Group opposes the adoption of the Commission’s proposal arguing that “the Commission has not met its burden of showing that the proposed position limit regime is ‘necessary’ and ‘appropriate.’ The Commission, moreover, has failed to undertake a comprehensive cost-benefit analysis of its proposed rules, as required by statute. The Commission also ignores the wealth of empirical evidence supporting the view that the proposed hard position limits (and related aggregation policy and restrictive exemptions) would actually be counterproductive by decreasing liquidity in the CFTC-regulated markets which, in turn, would likely increase both price volatility and the cost of hedging especially in deferred months.”

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IntercontinentalExchange - March 28, 2011

Position Limits for Derivatives
March 28, 2011

From the comment letter:

ICE supports the position limits if properly applied. In promulgating final rules, the Commision should:

  • Maintain the current position limit regime by allowing exchange specific spot month position limits
  • Allow higher position limits for financially settled contracts
  • Adopt position limits for the nearby months to expiration instead of an all months position limit
  • Keep arbitrage and spread exemptions
  • Not implement onerous account aggregation rules
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Kansas City Board of Trade - March 28, 2011

Position Limits for Derivatives
March 28, 2011

From the comment letter:

"Given the tremendous growth in both volume and open interest in all three wheat markets in recent years, we support and encourage the Commission to adopt equal and reasonable legacy (specific numeric) position limits for the enumerated wheat contracts that will continue to serve the needs of our markets and promote expanded market use. The creation of disparate limits between these markets will only serve to impede rather than foster such growth. In addition, unreasonably restrictive limits will only serve to aide overseas markets in promoting their contracts as replacements for the U.S. wheat futures global benchmark contracts, similar to the movement of late to shift away from the U.S. dollar as the global currency." In regards to spot month position limits, KCBT takes "exception to a spot month formula based solely on deliverable supply, which will result in disparate limits across wheat markets and diminish liquidity through inter-market spreading during the spot month."

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Minneapolis Grain Exchange - March 28, 2011

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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Dr. John R. Morris & Dr. Lona Fowdur, Economists Incorporated - March 28, 2011

Position Limits for Derivatives
March 28, 2011

From the comment letter:

  • "Some aspects of the NOPR may be better suited for the idiosyncrasies of agricultural markets rather than the day-to-day realities of energy markets."
  • "The definition of bona fide hedges in regard to swaps trading may be overly restrictive and that they may in fact be detrimental to the efficiency and competitiveness of the energy market."
  • Prior interpretations of the CFTC's rules regarding bona fide hedging “provided flexibility for the Commission and the Designated Central Markets to review applications for bona fide hedging exemptions and make appropriate determinations that certain activities constituted bona fide hedging, even if there were not literally a later transaction in a physical marketing channel,” and that, in a prior interpretation of the old rule, the CFTC ruled that substituting later positions in physical marketing channels “is not a necessary or required condition of a bona fide hedge.”
  • Citing to the CFTC’s own interpretation of the Dodd-Frank Act: “the CEA places ‘no restriction on the Commission’s ability to define bona fide hedging for swaps…’”
  • The proposals "show a bias of an agricultural-market view and ignore the dynamic realities of modern energy markets."

The comment letter provides specific examples of a natural gas pipeline transportation hedge and a natural gas storage facility hedge, and recommends "that the Commission’s proposed definition for bona fide hedges either acknowledge that pipeline and storage hedges constitute bona fide hedges or that the definition, as it applies to swaps, be modified to allow for legitimate hedge transactions like pipeline and storage hedges to take place without the need for a subsequent physical cash transaction."

The letter closes with recommendations that the commission:

  • "revise the proposal to allow for anticipatory hedges, and
  • redesign the reporting process for bona fide hedging exemptions so that it is efficient and commercially practicable."
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Working Group of Commercial Energy Firms - March 28, 2011

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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BlackRock - March 28, 2011

Position Limits for Derivatives
March 28, 2011

From the comment letter:

BlackRock believes that “the Commission’s proposed rescission of its independent account controller approach to position aggregation and its replacement with a flawed alternative, would have major adverse impacts on our asset management business without any corresponding public benefits. Position holders and owners, as well as asset and fund managers that have authorized professional advisors to control their trading can not affect market prices and should not be subject to aggregation. If the Commission decides that federal position limits are necessary and appropriate at all, we strongly urge the Commission to reconsider its aggregation proposal and to return to its traditional policy of focusing on who controls trading.”

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Shell Trading - March 28, 2011

Position Limits for Derivatives
March 28, 2011

Shell Trading offers several serious concerns about the proposed rule, arguing that “the proposal may prevent large hedgers from effectively managing their commercial risks. This results from a reduction in the size of spot position limits, the inclusion of a large (but largely undefined) number of instruments under those limits, a restrictive hedge exemption process, and uncertainty about the treatment of inter-affiliate swaps. Just as important, Shell Trading believes that the rule is overly complex and contains many ambiguous provisions, and accordingly, exposes market participants to grave unnecessary costs and compliance risks. Examples of the complexity and ambiguity include the number of position limits applicable to each derivative contract, the lack of clarity about which contracts will be counted towards each limit, and the fact that these limits will be enforced in real-time.”

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Hess Corporation - March 28, 2011

Position Limits for Derivatives
March 28, 2011

From the comment letter:

Hess believes that the Commission “should not treat the mere existence of a guaranty as a ‘proxy’ for trading control. Aggregating positions anytime a payment guaranty, lien, letter of credit, or other standard credit arrangement exists between two parties would be over-broad and inconsistent with the purposes that position limits were meant to serve.” They further argue that “consolidated financial statements do not demonstrate actual common control by the parent over the day-to-day trading decisions of its subsidiary. A rule that aggregates positions based on the accounting systems would, without more, be unnecessarily broad and an inefficient way to implement the intended purposes of position limits provision in the CEA.”

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Coalition of Physical Energy Firms - March 28, 2011

Position Limits for Derivatives
March 28, 2011

From the comment letter:

“COPE requests that the Commission not move forward with a final position limits rule. The Position Limits NOPR is not supported by empirical evidence and will impose a significant compliance burden on traders, their compliance personnel, and regulators alike. The Commission's already significant burden of market surveillance and enforcement, as increased by mandatory Dodd-Frank rulemakings, will only be further strained by unnecessary imposition of discretionary position limits that will prove as difficult to enforce as they will be to comply with. Rather than continue to pursue a position limits rule, the Commission should focus its resources on the mandatory aspects of Dodd-Frank and not burden itself and market participants with additional and questionable compliance obligations.”

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Cargill - March 28, 2011

Position Limits for Derivatives
March 28, 2011

From the comment letter:

“Cargill's business will be significantly affected by the Proposed Rules. The hedge exemption is vital to Cargill's management of its commodity price risk in its business activities as a purchaser, processor and seller of physical commodities. In tum, Cargill's ability to manage its own risk impacts the prices it pays to agricultural producers who supply commodities to Cargill, as well as the prices it charges to processors and end-users who buy from Cargill. Position limits and the hedge exemption are also important for Cargill's business of providing risk management services to other businesses, by acting as a swap counterparty to businesses using swaps to hedge their risks.”

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Futures Industry Association (FIA) - October 1, 2010

Pre-Rulemaking Position Limit Comments and Recommendations
October 1, 2010

From the letter:

FIA recommends that the CFTC "propose interim rather than final position limits on contracts involving exempt and agricultural commodities. FIA also recommends that any interim position limits apply only to net positions in economically equivalent contracts and be set at a level that will not reduce market liquidity or cause a migration of the price discovery function to foreign markets." FIA also recommended an "interim rule that aggregates positions only in commonly controlled accounts."

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United States Commodity Funds - October 21, 2010

Advance Comments on Position Limits and the Definition of "Major Swap Participant" Under the Dodd-Frank Wall Street Reform and Consumer Protection Act
October 21, 2010

The comment letter, posted October 21, 2010, is the second on the topic from USCF and opposed position limit proposals from the CFTC. The letter notes:[2]

"We continue to believe that the ability of USCF (and other firms that manage similar publicly traded, un-levered, passive commodity funds) to prudently meet the investment objectives of the commodity pools that it manages will likely be significantly hampered by the imposition of restrictive limits. We also believe that the significant additional regulatory requirements to which USCF and the Funds would be subject if USCF or any of the Funds are deemed to be "major swap participants" under the Act would similarly hamper the ability of USCF to efficiently meet the Funds’ investment objectives. As a result, and more importantly, the value of the exchange traded pools managed by USCF to the hundreds of thousands of investors in our pools, and the several million investors in all similar pools currently in operation in the United States, could be adversely affected by both (1) the adoption of the Dodd-Frank Position Limits and (2) classification of USCF as a major swap participant under the Act."

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NextEra Energy Power Marketing - October 21, 2010

Aggregation of Position Limits under Section 737 of Dodd Frank Act
October 21, 2010

From the letter:

"We are specifically concerned that an overly broad drafting of the rule regarding the aggregation of position limits...could have unintended consequences resulting in violations of certain federal and state laws applicable to energy companies."

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CME Group - October 25, 2010

Pre-Rulemaking Position Limit Comments
October 25, 2010

From the letter:

"Our comments regarding the Commission's § 4a position limit authority will focus on: 1) the statutory requirements for the Commission's establishment of position limits, and 2) the features the Commission should adopt for any necessary position limit regime (e.g., timing, exemptions, and aggregation standards). In offering these comments, CME Group has been cognizant of the extensive demands that are being made on the Commission‟s limited resources. However, the Commission must gather critical data regarding swap markets and individual traders‟ swap positions. Without a thorough understanding of such data, the Commission runs the risk of inappropriately setting position limits. CME Group appreciates the great challenge this presents to the Commission and suggests in this letter ways to reduce the strain on the Commission‟s resources while still serving our mutual goal of effective market surveillance to deter price manipulation and other abusive practices."

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GFI Group - January 27, 2011

RIN 3038-AD15 and 3038-AD16 Position Limits for Derivatives
January 27, 2011

Michael Cosgrove, Managing Director of GFI Group, Inc., submitted this letter to the CFTC on January 27, 2011. Mr. Cosgrove disputes the "conventional wisdon" that excessive speculation was to blame for the 2008 spike in commodity prices. He further suggests that, while position limits are "necessary for the smooth functioning of physically deliverable commodities", position limits on cash settled markets are "disruptive, dangerous, and of no positive value."

Cosgrove recommends withdrawal of the proposal with regard to cash-settled contracts, a tightening of the position limits for physically-delivered products, and a longer review period before a final rule is established.

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Gresham Investment Management - February 14, 2011

RIN 3038-AD15 and 3038-AD16 Position Limits for Derivatives
February 14, 2011

Henry Jarecki, Chairman of Gresham Investment Management LLC, submitted this letter to the CFTC on February 14, 2011. Dr. Jarecki argues with the categorization of Gresham as a "speculator, in the same status as the unconstrained and highly leveraged futures traders for whom position limits were no doubt intended." He explains that the company's risk controls, client management, and unleveraged customer base should allow the firm relief from position limits, as they had been until 2009.

Jarecki further argues:

  • There is "no more than anecdotal evidence" that position limits would lower the prices of food, fiber, or mineral prices.
  • The "legacy limits" proposal creates an unnecessary implementation delay on limits where they are needed -- with leveraged speculators.
  • The bona fide hedger exemption creates an "unlevel playing field," as it relates to unleveraged entities such as Gresham and their providing of liquidity and price discovery to the market.
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Futures Industry Association - December 2, 2010

Position Reports for Physical Commodity Swaps
December 2, 2010

From the comment letter:

  • The commission is proposing to develop its report system "before it has had time to define what must be reported and precisely who must report, and before market participants have had an opportunity to build the infrastructure necessary to collect and protect the confidentiality of the required information."
  • "The burden of implementing the proposed transitional rule will greatly exceed the benefits to the commission and market participants."
  • "The reporting requirements under the proposed position reports rule are too broad."

The FIA letter concludes with a request for the implementation of a "modified special call" process during the transition.

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National Futures Association - December 2, 2010

Position Reports for Physical Commodity Swaps
December 2, 2010

From the comment letter:

NFA addresses one important issue raised in subsection D of Section ll of the Federal Reqister release whereby the Commission specifically requests comments relating to "any role that self-regulatory organizations could play in gathering positional data on paired swaps."

"The Commission has a well-established infrastructure to obtain the necessary information regarding exchange-traded futures. With respect to paired swaps, though, the Commission will need information from SEFs, contract markets trading swaps and swap data repositories. NFA could certainly play an important role in gathering and consolidating relevant data from those varied sources and transmitting that information to the Commission. While to date we have not attempted to detail exactly how NFA would perform this function we certainly have presented Commission staff with a conceptual framework for NFA to perform this role."

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Minneapolis Grain Exchange - December 2, 2010

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."
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References

  1. Morgan Stanley, CME pan CFTC position limits. Reuters. Retrieved on November 18, 2010.
  2. United States Commodity Funds -- Comments to Position Limits and Definition of Maj or Swap Participant. Sutherland Asbill & Brennan LLP. Retrieved on November 18, 2010.

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