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Ex Parte Meeting for Proposed Rule 78 FR 75680

  • Title:
    Meeting w/Noble

    Ex Parte No: 838
    Date: 5/15/2014

    Meeting Date:

    Thursday, May 15, 2014

    CFTC Staff:

    Matthew Hunter


    Stephen Sherrod


    Riva Adriance


    Harold Hild


    Christa Lachenmayr

    Organization(s):

    Noble Americas Corp.

    External Attendees:

    Salvatore Penna (Noble)


    De'Ana Dow (Capital Counsel)

    Additional Information:

    Topic:  Noble discussed its commercial business as a sugar producer, processor, and merchant.  Noble commented that additional transactions should be recognized as bona fide hedging positions, including cash and carry derivative positions (e.g., long front month in futures, short next deferred month in futures), anticipatory merchandising, and fixed vs. floating basis positions. Such anticipatory transactions should be recognized as bona fide through the last trading day. Noble commented position accountability levels are preferred to hard limits.

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