Comment Text:
The Commission’s efforts to implement the Dodd-Frank Act are hopeful, however, I am gravely concerned about the need to limit excessive speculation in food and energy commodities.
Olivier DeSchutter, the UN Special Rapporteur on the Right to Food, has expressly stated in his report of September 2010 that a large percentage of the recent volatility in this market is due to a speculative bubble. Furthermore, many who historically have not invested in food based commodities, nor are concerned about agricultural essentials, have entered this market through the purchasing of derivatives.
I urge the Commission to implement the proposed rules in regards to aggregate speculative position limits to prevent excessive speculation. During this period of economic turmoil, speculators should not be overly influencing food and energy costs.
Congress called for exemptions from these limits for bona fide hedgers. I ask that the Commission define that term in the strictest sense possible. Banks, hedge funds, private equity and all passive investors in commodities should not be deemed as bona fide hedgers.
As an organization that seeks justice and sustainability across the globe through our investments, we ask that the Commission consider these concerns and act accordingly.
