Comment Text:
I am a retired legal services attorney interested in encouraging enactment of financial reforms which will benefit the general public and the stability of markets in the future. In order to avoid food and energy price bubbles, the proposed speculation limits must be implemented, and exemptions should be given only to dealers in physical commodities. Exemptions to banks, hedge funds or other financial players would be completely counter-productive.
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 and I urge the Commission to implement the proposed rules regarding aggregate speculative position limits to prevent excessive speculation.
I ask the Commission to define the term "bona fide hedgers" 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 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 bona fide hedgers.
Thank you for your consideration.
