Comment Text:
As manager of a feed mill I trade both hedgeable and non hedgeable commodities extensively, using thousands of futures contracts each year. I fully support the National Grain and Feed Association position on Position limits for derivatives, RIN 3038-AD99. We use diverse futures and options strategies to manage price, basis and spread risks. The existing definitions and interpretations of acceptable hedging strategies have worked well. Restricting the use of long accepted strategies could force businesses to widen their operating margins with the unwelcome result of lower prices to farmers.
