Comment Text:
I am pleased that the Commission is endeavouring to implement the Dodd-Frank Act. My particular concern are the reforms geared towards limiting speculation in food and energy commodities. Excessive speculation is clearly one of the key contributors to food price inflation, as shown by numerous research studies from repubable universities including Princeton, MIT, Yale and the University of London as well as organisations such as Citigroup, Petersen Institute, UNCTAD, FAO, and the US Senate. Strong implementation is crucial to ensure the world's poor are able to eat adequately and that their children's physical and cognitive development is not impaired - which is often the case when nutrition is insufficient, even for a short period of time.
I therefore ask the Commission to implement fully the proposed rules on aggregate speculative position limits. Congress has asked for exemptions from these limits for 'bona fide hedgers'. I urge the Commission to provide a clear and narrow definition of this term, such that it applies only to businesses that deal in physical commodities and use markets to hedge commercial risk. This should not include banks, hedge funds, private equity, passive investors in commodities or institutions hedging price directional bets such as commodity index swaps, Exchange Traded Funds and Exchange Traded Notes.
Dr Nicola Ansell
Uxbridge
UK.
