FIA filed a comment letter with the Commodity Futures Trading Commission (CFTC) today in response to the Commission’s supplemental notice of proposed rulemaking regarding exemptions from speculative position limits.
FIA supports the Commission’s proposal to rely upon the expertise of the exchanges to recognize non-enumerated hedge exemptions, spread exemptions, and anticipatory hedge exemptions consistent with the Commission’s guidance. FIA also supports the Commission’s proposal to delay exchange-set position limits for swaps. However, FIA believes that certain aspects of the Supplemental Proposal would inhibit the ability of exchanges to establish, or market participants to benefit from, the bona fide hedges that the Commission is seeking to make available. Accordingly, FIA recommends modifications to the Supplemental Proposal that are intended to implement the requirements of section 4a of the Commodity Exchange Act, as amended (CEA) and, at the same time, to lessen the administrative burdens on market participants, the exchanges and the Commission.