Comment Text:
Hunton & Williams LLP, on behalf of The Working Group of Commercial Energy Firms, and Sutherland Asbill & Brennan LLP, on behalf of The Commercial Energy Working Group, hereby submit these comments in response to the Commodity Futures Trading Commission’s (the “Commission”) request for public comment set forth in the Notice of Proposed Rulemaking, Aggregation, Position Limits for Futures and Swaps.
The Working Group of Commercial Energy Firms and The Commercial Energy Working Group appreciate the opportunity to provide comments on the Proposed Rule and respectfully request that the Commission consider the comments set forth herein as it develops a final rule in this proceeding.
Respectfully submitted,
Mark W. Menezes & David T. McIndoe