Comment Text:
The Honorable Timothy G. Massad, Chairman
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
202-418-5000
202-418-5521, fax
202-418-5514, TTY
Re: CFTC Should Abandon Proposal to Give For-Profit Corporations Regulatory Authority Over Markets/Dodd-Frank Rule Is Designed to Protect Consumers From Energy Price Spikes/COMMENTS FOR PROPOSED RULE 81 FR 38458
Dear Chairman Massad:
A proposal to give for-profit corporations some regulatory authority over markets should be abandoned. The proposal is related to a “position limits” rule required by the Dodd-Frank Act. The rule is designed to protect consumers and limit excessive speculation by preventing a small group of traders from dominating the market.
The CFTC proposal would give exchanges authority to determine hedge exemptions from federal position limits. This would place the clearinghouse corporations in a conflict of interest. Such a move also would subvert the CFTC to a lessor, after-the-fact regulator of position limits.
If the exchanges are to be involved at all in granting hedge exemptions to position limits, it should be limited to an advisory capacity, with both the initial, and final, hedge exemption determinations made by CFTC staff. CFTC should abandon allowing for-profit, corporate exchanges from having any role in granting hedge exemptions to federal position limits other than in an advisory capacity. The CFTC alone must be the agency determining hedge exemptions for federal position limits.
Re: Public Citizen comments: http://comments.cftc.gov/PublicComments/ViewComment.aspx?ID=60940&GUID=f2f05c68-1545-4b31-8bd7-fc9b23b1cf7c
Thank you for the opportunity to bring these remarks to your attention.
Yours sincerely,
Robert E. Rutkowski
cc:
House Democratic Whip Office
