Comment Text:
On behalf of the Working Group of Commercial Energy Firms (the “Working Group”), Hunton & Williams LLP hereby submits these comments in response to the request for public comment set forth in the Commodity Futures Trading Commission’s (the “CFTC” or “Commission”) Notice of Proposed Rulemaking, Position Limits for Derivatives (the “Proposed Rule”), published in the Federal Register on January 26, 2011, which establishes position limits for certain physical commodity derivatives pursuant to newly amended Section 4a(a) of the Commodity Exchange Act (“CEA”), as established by Section 737 the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank” or the “Act”).
The Working Group is a diverse group of commercial firms in the energy industry whose primary business activity is the physical delivery of one or more energy commodities to others, including industrial, commercial, and residential consumers. Members of the Working Group are energy producers, marketers, and utilities. The Working Group considers and responds to requests for public comment regarding regulatory and legislative developments with respect to the trading of energy commodities, including derivatives and other contracts that reference energy commodities.
The Working Group appreciates the opportunity to provide these comments. If you have any questions, please contact Michael Sweeney, Mark Menezes, or David McIndoe.
Respectfully submitted,
Meghan R. Gruebner
