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Comment for Proposed Rule 78 FR 75680

  • From: Greg Hennenfent
    Hennenfent Advisory LLC

    Comment No: 59496
    Date: 1/15/2014

    Comment Text:

    Speculation is another word for liquidity in the commodity markets. Putting an "All Months" limit equal to the "Single Month" limit does not make sense for the trader/speculator nor the industry. Liquidity is critical for the commodity sector. Those who provide liquidity are the floor traders, screen traders, and high volume proprietary traders. The markets are there to establish price--and coming from a farm background and having financed the food industry for decades--- are critical to help producers, processors and consumers manage risk across the ag and food supply chain. Liquidity, albeit also good for the exchanges, is needed to ensure the ability to manage risk and margin across the industry. Traders and speculators are an important component of this.

    I do not suggest knowing the answer, but strongly believe that having the "All Months" limit equal to the "Single Month" will negatively restrict liquidity and price discovery. Please listen to the views of the commercial participants who actively use the markets to manage risk/margin (farmers, packers, processors, retailers, and their brokers & bankers) as their fundamental participation in the market makes up its foundation.

    Gregory Hennenfent--Mr. Hennenfent is President of Hennenfent Advisory LLC. Hennenfent Advisory provides corporate development, corporate finance, acquisition and growth strategy services. Mr. Hennenfent has over 27 years of experience in the finance and investment community with specific emphasis in the food, risk management, farmland and agribusiness sectors. In addition to consulting to grain, healthcare, farm management, food processing, technology and land investment businesses, prior positions held by Mr. Hennenfent include: Managing Director of Credit Agricole Corporate & Investment Bank's North American Food & Agribusiness, Director at the CME Group-Livestock, Dairy and Fertilizer team lead, Regional Director--Food & Agribusiness Team for John Hancock’s Bond and Corporate Finance Group, Vice President of Harris Bank’s Food & Agribusiness Group, and senior roles in American National Bank's middle market and national asset-based lending groups. Mr. Hennenfent has a Master’s of Business Administration from DePaul University Kellstadt Graduate School of Business and a Bachelor of Science degree in Agricultural Industries from the University of Illinois, Urbana-Champaign.

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