Position Limits Regulation - 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.
- 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."