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Comment for Proposed Rule 76 FR 4752

  • From: Beatrice Greenfield
    Organization(s):
    Friends of the Earth
    Stop Climate Chaos
    Big Climate Connection

    Comment No: 32086
    Date: 3/22/2011

    Comment Text:

    a. In order to avoid food and energy price bubbles, the proposed speculation limits must be implemented. b. Only give exemptions to businesses that deal in physical commodities (like farmers, gas stations, etc.). Do not give any exemptions to banks, hedge funds or other financial players.
    The last time that the hedge funds operators (bone fide or otherwise) bet on food prices thousands died. Can you really believe that this sort of specualtion can have no effect? The only effect that they are interested in is profit but when you are dealing with food poverty this should not be an option; the millions that did not die are sitll trying to recover from that crisis. If you allow the hedge fund operators to call for exemptions then you will have to work out how to spend your 12 pieces of silver.It will be on your conscience.

    I applaud the Commission’s efforts to implement the Dodd-Frank Act as thoroughly as possible especially reforms aimed at limiting excessive speculation in food and energy commodities.

    While many factors contribute to today’s highly volatile commodity prices, it is clear that excessive speculation is partially responsible, as shown in dozens of studies by members of respected institutions such as Princeton, MIT, Citigroup, Petersen Institute, University of London, Yale, UNCTAD, FAO, and the U.S. Senate.

    I urge the Commission to implement the proposed rules regarding aggregate speculative position limits to prevent excessive speculation. At this time of fragile economic recovery, we cannot allow speculators to unduly affect our food and energy prices.

    Congress called for exemptions from these limits for bona fide hedgers. I ask that the Commission define that term in the strictest sense possible, limiting exemptions to businesses that deal in physical commodities and use markets to hedge commercial risk in those commodities. Banks, hedge funds, private equity and all passive investors in commodities should not be deemed as bona fide hedgers. Institutions hedging price directional bets such as commodity index swaps, Exchange Traded Funds and Exchange Traded Notes also should not be considered as bona fide hedgers.

    Thank you for your consideration.
    Beatrice Greenfield

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