Comment Text:
Gentlemen;
Please consider a revision to the proposed rule which allows the grandfathering of existing positions regardless if they are in excess of the new limits.
The intent of the proposal is to achieve a free market valuation of commodities. The allowance of an existing position that by itself acts to inhibit true price equilibrium effectively weakens the rule. Much effort has gone in to arriving at acceptable position limits in terms of their impact on true market prices. Giving an exemption for outsized positions merely due to the date of their inception does nothing but essentially endorse what the committee has now determined to represent market manipulation. I believe a more substantive solution would be to require the liquidation of excess positions over a suitable time period.
Thank you.
John Cassidy
