Comment Text:
On behalf of The Commercial Energy Working Group , Sutherland Asbill & Brennan LLP hereby submits these comments in response to the request for public comment set forth in the Commodity Futures Trading Commission’s Notice of Proposed Rulemaking, Aggregation of Positions. These comments should be considered in conjunction with the Working Group comments to the Commission’s Notice of Proposed Rulemaking, Position Limits for Derivatives, as there are numerous instances where the two proposals are interdependent.
