Comment Text:
Our Cooperative fully supports change in regards to full carrying charges as we have gone nearly 3 years without getting convergence on corn or soybeans. Our patrons are growing frustrated using the Board of Trade as a hedging tool as our cash basis continues to be extremely wide. We would suggest some hybrid of the current wheat VSR with an observation period in Corn from Dec-March each year and soybeans from November to January. If 80% of full carry is averaged over those observation periods, then an adjustment could be made increasing rates and likewise if the average carry is less than 50% an adjustment lower would be warranted until the annual periods stated earlier.