Comment Text:
I have worked in the grain industry for the past 12 years, and through that time I have worked in both commercial grain merchandising and farmer origination and risk management. The need for VSR in the corn and soybean markets is critical when managing farmer risk. Non convergence and extreme basis levels nullify much of the benefit of federal crop insurance, whose pricing is set based on futures prices alone. VSR not only helps the commercial grain elevator, but is critical to the function of futures markets for our country's producers. I would also be in support of an annual review period instead of the contract month review that is currently in use in wheat.
