Position Limits Regulation - Futures Industry Association (FIA) - October 1, 2010

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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.
  • 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."
  • Implement an "interim rule that aggregates positions only in commonly controlled accounts."


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