Comment Text:
It is my understanding that the CFTC is considering new rules that would affect the way our company risk manages our grain. In particular, anticipatory hedging where our company manages carry charges by locking in our spread risk. This has been a long-accepted risk management strategy employed by not only our firm but most every firm in the grain industry. By restricting the use of these long accepted strategies, this proposed change will not only increase risk to our company, but drive up costs, which in turn will be translated to lower bids to farmers and higher offers to end users. We are opposed to this change as presently being considered today. We would be happy to explain further at your request.
Thank you for allowing us to comment on this.
