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Comment for Industry Filing 18-001

  • From: steve mcwhirter
    Organization(s):
    CPI, Hastings, ne

    Comment No: 61702
    Date: 8/9/2018

    Comment Text:

    the lack of futures and cash convergence in todays market has been an ongoing issue. it effects and penalizes commercials, bankers and farmers as well. with crop insurance indemnity to the farmer in a low basis market, the indemnity is reduced by the amount of nonconvergence since it uses the futures value rather than cash values.
    if one would use a modified vsr with a yearly observation period with the base storage rate of 8c/bu/month and then could widen to maybe 13 cents if needed. this would help convergence and allow quicker response to changes in the market

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