Comment Text:
i0-002
COIMMENT
CL-08269
From:
Sent:
To:
Subject:
Attach:
Susan Ginsberg
Monday, April 26, 2010 6:52 PM
secretary
Comments on Federal Speculative Position Limits
IPAA comments 4 26 2010.pdf
Attached please find the comments of the Independent Petroleum Association of America on the Proposed Rule
to implement Federal Speculative Position Limits for Referenced Energy Contracts and Associated Regulations.
Thank you.
Susan W. Ginsberg
Vice President
Crude Oil & Natural Gas Regulatory Affairs
Independent Petroleum Association of America
www.ipaa.org
/ [email protected]
/ 202.857.4728
IPAA Access Direct Blog: http://www.ipaa.org/blo,q/
IPAA
represents the companies that drill 90percent of America's onshore and offshore oil and natural
gas wells.merica's Oil & Gas Produce~
April 26, 2010
Mr. David Stawick, Secretary
Commodity Futures Trading Commission
1155 21
~t
Street, NW
Washington, DC 20581
RE:
Comments of the Independent Petroleum Association of America
On Federal Speculative Position Limits for Referenced Energy
Contracts and Associated Regulations
Dear Mr. Secretary:
The Independent Petroleum Association of America (IPAA) represents the thousands of
independent producers of American natural gas and oil. IPAA supports efforts to increase the
transparency and oversight of derivatives markets. However, we urge caution in this proposed
rulemaking, given the concurrent congressional efforts to enact financial reform.
As noted during the hearing leading to this rulemaking, a new rulemaking would be necessary
should the CFTC be granted jurisdiction over the over-the-counter market. Given the resources
to be invested by the CFTC and regulated industries in complying with new rules, IPAA suggests
that the CFTC should refrain from imposing a new regulatory and compliance regime that might
be supplanted shortly thereafter by the need for another rulemaking in light of added CFTC
authority.
IPAA's caution should not be mistaken for resistance to greater transparency and oversight of
commodity markets to ensure their proper functioning. IPAA views speculation as vital to the
functioning of commodity markets. IPAA looks forward to working with the CFTC, following
congressional action on financial reform, to ensure that aggregate speculative position limits
across multiple markets prevent excessive speculation and support strong, competitive
commodity markets.
Lee O. Fuller
Vice President of Government Relations
Independent Petroleum Association of America~1201
15
th
Street, N.W., Suite 300 Washington, DC
20005
(202) 857-4722 ~ Fax (202) 857-4799 ~ www.ipaa.org
