Comment Text:
Pure Line Food Company is a small country grain elevator. My position in the company allows me to purchase and sell grain on a daily basis. For the first 20 years of working here, I did not utilize the CME grain futures markets in price risk management. I was a bona fide "back to back" seller.
For the last 17 years, I have become a bona fide "basis trader" and utilize the CME grain futures each and every day.
It has been a win-win for the company and our customers being able to hedge our position and take the bulk of price risk out of the equation without worrying about a hedge transaction being considered a bona fide hedge. In my opinion, taking away my ability to hedge my position is a step backwards in time.
I urge the CFTC to revise the proposed language to maintain a broader definition of what a bona fide hedger is and what activities they may do.
