Comment Text:
To Whom It May Concern:
I agree fully with the recommendation letters put forth by the NGFA Risk Management Committee signed by the honorable chair MF Anderson. To my knowledge, the understanding of the CFTC is incomplete in regards to commercial grain risk management.
It would seem prudent to this grain merchant that the CFTC does more to advance their understanding of all the current uses of the futures market to better flesh out why trades are made including but not limited to the following anticipatory hedging activities:
• Locking in futures spreads;
• Hedging basis contracts;
• Hedging delayed-price commitments;
• Cross-hedging;
• Anticipatory hedging of commercial transactions
• Anticipatory hedging of processing capacity
Limitations to the risk management grain merchandising community will punish farmers and the grain industry as a whole if it is not done properly.
Best,
Brian Liedl
