Comment Text:
I supported the passage of the Dodd-Frank Act. It is important that it be implemented in totality but especially reforms aimed at limiting excessive speculation in food and energy commodities.
Excessive speculation is the primary contributing factor to the current high volatility in commodity prices. This has been shown in many 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. 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.
Deborah Kair
33 Fieldstone Dr C1
Hartsdale NY 10530
