Agricultural Swaps Regulation - Comment Letter - Cargill Risk Management - October 27, 2010

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Agricultural Swaps ANPRM
October 27, 2010

From the comment letter:

"Agricultural swaps and OTC options have served the public good by allowing agricultural producers and processors to hedge their commodity price exposure economically and efficiently. Given that agricultural swaps have performed well, and that additional protections for all swaps arc established under Dodd-Frank, we see no need or purpose for imposing additional regulatory requirements on agricultural swaps and options.

"Any additional requirements would discourage and make the use of these instruments less economical, penalizing hedgers seeking to mitigate risk. In implementing the provisions of the Dodd-Frank Act, therefore, the Commission should adopt rules that would encourage the continued use of these valuable hedging tools. Consideration should be given to expanding hedging opportunities by allowing agricultural trade options to non-ECPs, provided the additional protections above are also established for this category of end-user."


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