Comment Text:
Attebury Grain, LLC (Attebury Grain) each year provides daily price discovery to thousands of producers. Our ability to do so relies on hedging transactions to manage risk at the lowest possible cost.
Attebury Grain agrees with the NGFA statements on these proposed changes. Furthermore, Attebury Grain views the CFTC-proposed rule changes as narrowing the range of hedging transactions that would be considered bona fide hedges.
The proposed definition would make many of the hedging transactions which Attebury Grain has employed since its founding in 1954 outside definition of bona fide hedges.
The ability to forecast our business and hedge the associated risks with purchases of producer grain outside trading hours of a futures exchange is critical. Furthermore, being able to hedge carrying charge risk associated with storing inventories, until the market demands the product, through the futures market is also critical.
Utilization of these long-accepted hedging strategies have been the backbone of keeping the cost of doing business low. Restricting the use of these tools will ultimately will lead to lower bids to the producers, with whom we do business, and ultimately lead to higher consumer prices.
