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Comment for Proposed Rule 85 FR 11596

  • From: Ronald Lawson
    Organization(s):
    Lawson/O’Neill Global Institutional Commodity (LOGIC) Advisors

    Comment No: 62530
    Date: 5/11/2020

    Comment Text:

    As a commodity Futures and Options professional for over 38 years, I have seen a marked change in the availability of data and information over the years. Prior to the advent of the internet, only large market participants with ample capital had the ability to gather information from the cash markets that would allow for insight that would provide a competitive advantage. The rest of the trading public had only government's reports to fall back on, such as the On-Call and Commitment of Traders' Reports.

    A significant consolidation over the past 15 years, has resulted in only a few large companies left within each sector of the Cotton business. Therefore, even with the tsunami of information flowing across the internet, the few remaining government reports have become increasingly vital to the vastly greater number, of smaller market participants. Already, the elimination of the ICE's Spec/Hedge Report has dimmed the light shining on which sector of the Market is long or short.

    It has become apparent that the general trading public has been relatively disadvantaged by the quantitative algorithmic computer trading models that can react in a micro-second to news, much faster than any human. Now, it is being proposed that the On-Call Report be eliminated, eliminating the chance for traders to decipher participant trends, and thereby reducing further, the transparency of the Cash-market to Futures-market correlation and price convergence.

    The more information that is made available to the greater number or market participants, the more accurate and correlative will conditions remain. To eliminate the On-Call Report leaves the Market relatively more prone to manipulation and imbalance of equal opportunity to all traders, large and small. I strongly urge that the On-Call Report continue to be generated and distributed.

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