Comment Text:
I heartily approve of the Commission’s efforts to implement the Dodd-Frank Act as thoroughly as possible, especially those reforms aimed specifically at limiting excessive speculation in food and energy commodities.
Although many factors contribute to today’s highly volatile commodity prices, clearly excessive speculation bears partial responsibility, as shown in many of studies by members of respected institutions such as Princeton, MIT, Citigroup, Petersen Institute, University of London, Yale, UNCTAD, FAO, etc., as well as the U.S. Senate.
I strongly urge the Commission to implement the proposed rules regarding aggregate speculative position limits to prevent excessive speculation. At this time in our nation's fragile economic recovery, we cannot allow speculators to have an undue impact on 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.
Elizabeth Claman
Richmond, California 94801
