Comment Text:
Comments of the International Energy Credit Association on CFTC "Position Limits for Derivatives and Aggregation of Positions," (including the Aggregation Proposal, 78 FR 68946 (published November 15, 2013), and the Position Limits Proposal, 78 FR 75680 (published December 12, 2013), referred to collectively as the "Proposed Rules"), RIN 3038-AD99; 3038-AD82, Extension of Comment Periods, 79 FR37973 (published July 3, 2014)
