Comment Text:
To whom it may concern:
I am pleased to see the Commission is moving towards an exhaustive implementation of the Dodds-Frank Act, including the reform aimed at curbing excessive speculation in food and energy commodities.
There is extensive, robust evidence to illustrate how unrestricted speculation in commodities and energy prices is a contributing factor to highly volatile commodity prices, from respected bodies including: MIT, Citigroup, Petersen Institute, University of London, Yale, UNCTAD, FAO, and the U.S. Senate.
I call upon the Commission to apply the proposed rules regarding aggregate speculative position limits to prevent excessive speculation.
I am aware that Congress supports exemptions from these limits for bona fide hedgers. I further call upon the Commission to develop a strict definition of this term. Exemptions should only be for 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 considered bona fide hedgers. Nor should institutions hedging price directional bets including commodity index swaps, Exchange Traded Funds and Exchange Traded Notes.
Thank you for your interest in this matter.
Kate Robinson
