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Comment for Proposed Rule 76 FR 6095

  • From: jc hoyt

    Comment No: 35340
    Date: 3/31/2011

    Comment Text:

    Regarding position limits I would like to see the CFTC promote the implementation of Liquidity Data Bank (LDB) as tool of transparency. When I say Liquidity Data Bank (LDB), think of an hour-by-hour snap-shot of the current Commitments of Traders (COT)
    This added level of transparency would allow the public to see who is moving each market on an hour-by-hour and/or end of day report. This added level of data would then aid policy makers in their task to keep regulated exchanged traded products as viable tools for risk management.
    Take corn for an example, not only is this no longer a food commodity it is now tied to energy, and due to this you are seeing the movement away from the “on” exchanged futures hedging to the “off” exchange sites such as (Grainbridge, Farmstech, CMDirect, and DTN just to name a few) all are in the cash market space, keep in mind the cash grain market is highly unregulated when compared to the futures industry.
    I would like to see more transparency providing solutions for the futures industry.
    JC Hoyt

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