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Comment for Proposed Rule 77 FR 67866

  • From: Steve Solomon
    Organization(s):
    Solomon Metals Corp

    Comment No: 59077
    Date: 1/15/2013

    Comment Text:

    Solomon Metals Corporation is a non-ferrous scrap metal recycler established in 1943 with physical plant operations in Lynn, MA and Manchester, NH. The primary metals we handle are copper and copper and brass alloys. In this era of market volatility we must utilize futures contracts to mitigate the risk of market movements. When transferring margin requirements to support our positions we could never have anticipated that these funds were not totally 100% secure. The situation at MF Global proved to be very troubling and undermined the confidence in using these financial instruments. We appreciate the customer protections being proposed and would also like to strongly support the comments submitted by the Institute of Scrap Recycling Industries as well as Premier Metal Services as a means to further protect and options to customers of FCM's.

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