MFA Comment Letters

Topic: CBOT

Comment Letter to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

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Topics: CFTC Commodity Futures Trading Commission, position limits, derivatives, futures, option contract, swap contract, futures market, price risk, commercial participants, operating company, financial institution, energy market infrastructure, liquid price discovery, risk-shifting market, market manipulation, federal limits, crowding out provision, spot month, disaggregation relief, deliverable supply, inter-commodity spread transactions, bona fide hedger, price discovery, risk management, commodity market, annual recalculation methodology, U.S. futures exchange, delivery point, individual class rules, legacy position limits, agricultural commodities, disorderly markets, spot-month position limits, referenced contracts, aggregate spot-month position limits, swaptions, DCMs, physically delivered contracts, cash-settled contracts, conditional-spot month limit, cash position, forward position, physical commodity deliverable, aggregate all-months-combined, aggregate single-month, futures class all-months-combined, futures class single-month, swaps class all-months-combined, swaps class single-month, open interest, non-spot position limits, calendar-spread exemption, hedging transaction, cash market transaction, cash market risk, swap dealer hedge exemption, pool participant, future commission merchants, FCMs, independently controlled and managed trader, account aggregation requirements, enumerated agricultural commodities, open interest formula, position visibility, reporting requirements, offsetting positions, excessive speculation, interstate commerce, physical commodity, interest rates, stock indices, squeezes, market liquidity, global commodity, regulatory oversight, risk transfer, energy price volatility, CTFC Inter-Agency Task Force on Commodity Markets, GAO, IOSCO, IMG, UK Treasury, CME, The Economist, supply and demand, U.S. dollar, price volatility, NYMEX crude oil price, speculative investment, crude oil futures, International Organization of Securities Commission, IOSCO Technical Committee, IMF World Economic outlook, HM Treasury Global Commodities, OECD publishing, JP Morgan, long positions, hedge funds, short positions, Chicago onions, Berlin wheat, Credit Agricole, Energy Risk, University of Calgary, PKVerleger LLC, Wall St. Journal, Artificial limits, Barclays Capital, OECD Food, Jacks Study, Commission Energy Complex Report, Global Energy Management Institute, Bauer College of Business, University of Houston, House Committee on Agriculture, Pirrong Testimony, price spikes, agricultural model, metal commodity, seasonal variation, market surveillance, OTC, WTI, independently controlled accounts, independent third party, commodity trading advisors, common parent, CPO, CTA, control standard, commodity pool operator, commodity trading advisor, eligible entity, order routing arrangement, disclosure documents, non-financial entity exemption, active trading program, passive trading program, funds of funds, private equity investments, passive investors, pension plan, independent account controller exemption, asset manager, corporate enterprises, speculative trading ventures, CFTC docket no. 11-05, CFTC docket no. 08-02, pool participant exemption, equity interest, market depth, no-action relief, percentage interest, real-time basis, university endowment, liquidity provisions, application based exemption, approval based exemption, annual renewal based exemption, self-executing disaggregation, reporting obligation, surveillance, audit, enforcement, cross-ownership of traders, statement of reporting trader, benchmark contracts, NYMEX Henery Hub Natural Gas contract, commercial hedgers, inter-commodity spread exemption, arbitrage exemption, directional position, outright positions, submarket, large trader data, seasonality, annual limits, CBOT, NYBOT, KCBOT, pre-existing position exemption, significant price discovery contracts, index fund manager, class limits, rounding, hypothetical portfolios, cleared bilateral contracts, non-cleared bilateral contracts, front month position, deferred month positions, last day swaps, penultimate swaps, options, delta, financial cal spread options, physical cal spread options, physical options, HH natural gas,

Comment Letter to CFTC Responding to Proposed Regulations to Implement Federal Speculative Position Limits for Futures and Options Contracts04.26.10


MFA submitted comments to the CFTC in response to its request for comments on its proposed rule on Federal Speculative […]

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

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Topics: Federal Trade Commission FTC, Market Manipulation Rulemaking, futures group, Part 317, anti-manipulation protections, non-futures, wholesale markets, crude oil, gasoline, commodities, Manipulation, fraud proscriptions, Commodity Futures Trade Commission, CFTC, petroleum distillates, exclusive jurisidiction provision, safe harbor, federal register, exclusive jurisdiction provision, price discovery, forward market business activities, regulatory, CEA, anti-manipulation system, false reports, commodity prices, resource limitations, congressional grant, energy markets, John M. Damgard, Futures Industry Association, FIA, Jerrold E. Salzman, CME Group Inc., Thomas W. Sexton, National Futures Association, NFA, Jeffrey Sprecher, IntercontinentalExchange, ICE, Donald S. Clark, Advanced Notice of Proposed Rulemaking, wholesale purchase, options trading, energy futures, futures exchange, Chciago Mercantile Exchange Inc., Board of Trade of the City of Chicago, Inc., CBOT, new York Mercantile Exchange Inc., NYMEX, Commodity Exchange, COMEX, ICE Futures U.S., New York Board of Trade, ICE Futures of Europe, ICE Futures Canada, Winnipeg Commodity Exchange, over-the-counter energy trading platform, commercial market, limited-purpose national securities association, customer protection, merchants, brokers, commodity pool operators, commodity trading advisors, registered account executives, sugar, corn, ethanol, price effects requirements, compliance burden, U.S. Court of Appeals for the Seventh Circuit, Board of Trade of City of Chicago v. SEC, 677 F.2d 1137 (7th Cir. 1982), Chicago Mercantile Exch. v. SEC, 883 F.2d 537 (7th Cir. 1989), Board of Trade of City of Chicago v. SEC 677 F.2d 1137, 1145 (7th Cir. 1982), FTC v. Roberts, 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 592, chain of precedent, 276 F.3d at 591, SEC vs. Hopper, corporate disclosures, US vs. Reliant Energy Services, 420 F Supp.2d 1043 (N.D. Cal. 2006), exclusive regulatory authority, Federal Energy Regulatory Commission, FERC, instruments, accounts, Ken Roberts Co. v. FTC, No. 01-1772, 537 U.S. 820, 2002 WL 32135703, speculative limits, Energy Department, DOE, Environmental Protection Agency, EPA, emissions credit, Agriculture Department, USDA, Williamson v. United States, 512 U.S. 594, Trichilo v. Sec'y of Health & Human Servs., 823 F.2d 702, 706 (2d Cir. 1987), SEC v. American Commodity Exch., 546 F.2d 1361, International Trading Ltd. v. Bell, 556 S.W.2d 420 (Ark. 1977), Clayton Brokerage Co. v. Mouer, 531 S.W.2d 805 (Tex. 1975), Minnesota v. Coin Wholesalers, 250 N.W.2d 583 (Minn. 1976), Amaranth, statutory authority, non-petroleum based commodities, agricultural feed-stocks, price artificiality, contract markets, intermediaries, agents, counterparties, contractual privity, contradictory requirements, United States Congress, 2006 WL 778640 (S.D. Tex. March 24 2006),
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