Comment Text:
On behalf of the Working Group of Commercial Energy Firms, Hunton & Williams LLP hereby submits this letter to reiterate its comments on the Commodity Futures Trading Commission’s Notice of Proposed Rulemaking on position limits issued pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Specifically, the Working Group submits this letter to restate important policy considerations and concerns regarding the proposed spot-month position limit and conditional exemption for cash-settled contracts as set forth in proposed CFTC Rule 151.4(a).
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Respectfully Submitted,
Matthew C. Thomas
Government Affairs Specialist
Hunton & Williams LLP