Comment Text:
The CME review process is appreciated. However, the length of time has been 3 years to affect change to a problem that costs our company money. The lack of convergence penalizes all. But it affects those of us without large international networks the most. We need converging markets to accurately represent the grain markets. This will offer incentive to lenders to loan hedgers like myself the adequate funds we need to operate our business.
VSR solves the above problems, but a hybrid with 1 yearly observation period creates a simpler tool. The hybrid is simpler and requires no CME focus groups. I suggest using current VSR measures of 80% of full carry to provide a monthly deliverable storage increase of 5 cents/month.
Thank you for your consideration.
