Comment Text:
Please do not approve the staff's proposal on position limits for derivatives. The proposed formula is inadequate. The purpose of a formula is to ensure the limits are fair and consistent. There are no less than nine exceptions to the proposed formula. The existence of so many exceptions undermines the legitimacy of the formula. There would be no need for exceptions if the formula were legitimate.
All the exceptions apply to agricultural commodities. The staff can only justify this fact by arguing agricultural commodities are somehow unique. However, even the staff must agree that every commodity is unique in some way. It follows each commodity then deserves an exception, rendering the formula meaningless. In short, advocating exceptions is the same as rejecting the single formula that ensures consistency and fairness.
The commission should consider a formula whereby speculative position limits are equivalent to 1% of world production, for all commodities.
