Comment Text:
I would like to comment on the rulemaking of position limits and the definition of bona fide hedging. I have read the National Grain and Feed Association comments stated in their letter of August 4, 2014 and agree with their stated positions in their entirety.
At Tremont Coop Grain Co. we are a country elevator handling over 10 million bushels of corn and soybeans for over 700 producers. We provide services such as drying, storage, handling and merchandising of their products. In order for us to manage the associated risks it is necessary that we use the CBOT futures and options contracts to offset our risks in dealing with our producers. We use futures spreads extensively by locking in carry when the market offers carry and prepositioning cash sales when the market calls for it. We need the flexibility to ladder out our cash sales to manage our physical logistics. Narrowing the definition of bona fide hedging would harm our ability to manage the storage and handling of the grains for our producers and cause us to take other off-exchange positions that incur greater risks. This would not be in the best interests of the grain industry, farmer producers, and the end-users of grain.
submitted by Richard Sauder
General Manager
Tremont Coop Grain Co.
