Comment Text:
Lack of convergence in the cash markets, especially for soybeans, has caused a significant increase in risk for Northern Partners Coop and our producer member owners. I applaud the recent update of base storage rates by the CFTC to address this issue. However, we are all operating in a constantly changing trading and economic environment. Northern Partners Coop fully endorses an annual review period to ensure factors affecting convergence are monitored and addressed in a timely fashion.
Our company and our producers depend on fully transparent markets to mitigate risk, we encourage the CFTC to strongly consider an annual review of rates based off a single observation period each year.
Because of the current volatility of our global markets and the ensuing risk it creates, we strongly encourage this change as soon as possible.
