Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I urge you to approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. I would also ask you to make certain that large institutions are not able to circumvent these limits with the use of holding companies and subsidiaries, shell corporations, SIVs, and the like.
The purpose of speculative position limits is to prevent market manipulation. Such limits are meaningless if they can be outmaneuvered by creative accounting and legal structuring.
Respectfully submitted,
Sean Malowney
