Comment Text:
The efforts of the Commodities Futures Trading Commission to implement the Dodd-Frank Act as thoroughly as possible, are to be commended, especially implementing reforms aimed at limiting excessive speculation in food and energy commodities.
It is evident that excessive speculation is partially responsible for today's highly volatile commodity prices
- unduly affecting food and energy prices in this time of fragile economic recovery.
I want to urge the Commission to fully implement the proposed rules regarding aggregate speculative position limits to prevent excessive speculation.
Congress has called for exemptions from these limits for bona fide hedgers. I ask that the Commission define that term in the strictest sense possible, limiting exemptions to businesses that deal in physical commodities and use markets to hedge commercial risk in those commodities. Banks, hedge funds, private equity and all passive investors in commodities should not be deemed as bona fide hedgers. Institutions hedging price directional bets such as commodity index swaps, Exchange Traded Funds and Exchange Traded Notes also should not be considered as bona fide hedgers.
Thank you for your consideration.
Maureen O' Connell,
Mountmellick, Co. Laois, Ireland
