FIA provided the Commodity Futures Trading Commission with the comments and recommendations set forth below as a supplement to FIA’s prior comments filed in response to the Commission’s Notice of Proposed Rulemakings concerning Position Limits for Derivatives, 78 Fed. Reg. 75680 (Dec. 12, 2013) and Aggregation of Positions, 78 Fed. Reg. 68946 (Nov. 15, 2013). FIA appreciates the Commission’s willingness to reconsider various aspects of the Proposed Rules and to host the June 19, 2014 CFTC Staff position limits roundtable. The comments and recommendations below focus on issues raised in connection with the Roundtable. FIA incorporates by reference, where applicable, its prior comments to the Proposed Rules.
