Comment Text:
Comments of the International Energy Credit Association with respect to the CFTC's Re-Opened Comment Period for its Proposed "Position Limits for Derivatives and Aggregation of Position," 80 Fed.Reg. 10022 (February 25, 2015), as corrected 80 Fed.Reg. 15699 (March 25, 2015), RIN 3038-AD99; and RIN 3038-AD82