Comment Text:
We support CME taking notice of full carrying levels negatively affecting market convergence, but the mere fact that the review process is taking 3 years to adapt from the beginning of the problem to changing is unrealistic and helps nobody also noting we are still one year away from implementation. An alternative would be a solution similar to VSR with wheat in today’s market and the one-year observation period for Dec/March Corn and Nov/Jan Soybeans (80% of full carry provides an increase of 5 cents, while 50% of fully carry provides a decrease of 5 cents). This option would make the most sense for everyone and would allow the determination of storage on an annual basis based off true market conditions during those time frames.
