Comment Text:
Attached please find comments on the Notice of Proposed Rulemaking: Speculative Position Limits for Derivatives, 85 Fed. Reg. 11596, RIN 3039-AD99 (February 27, 2020), and a Request for an Exemption from such Speculative Position Limits Rules.
Respectfully submitted by:
Patricia Dondanville, Croke Fairchild Morgan & Beres, on behalf of:
National Rural Electric Cooperative Association
American Public Power Association
American Public Gas Association
