Comment Text:
I support a dynamic CME corn and soybean deliverable storage rate. It would help eliminate the ad hoc nature and politics that are part of the current process.
The CME contract review process is taking 3 years to affect change from beginning of problems to change. This can result in changes well after a convergence issue develops.
Lack of convergence penalizes all, but affects those without large international networks to offset their risk the most.
If a crop insurance indemnity is due to farmers in a low basis environment, that indemnity is reduced by the amount of non-convergence since crop insurance reference prices utilize futures values rather than cash values.
Non-converging markets reduce lenders’ willingness to provide credit for hedging.
Thank you for consideration of these comments.
