Comment Text:
The American Petroleum Institute (“API”) respectfully submits the attached comments in response to the notice of proposed rulemaking issued by the Commission concerning the aggregation of position limits for futures and swaps. See Notice of Proposed Rulemaking, Aggregation, Position Limits for Futures and Swaps, 77 Fed. Reg. 31,767 (May 30, 2012) (the “Proposed Rules”).
