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

April 26, 2010

From: MFA, Richard Baker


David A. Stawick, CFTC
Gary Gensler, Michael Dunn, Bart Chilton, Jill Sommers, Scott O'Malia, Stephen Sherrod, David Van Wagner, Donald Heitman, Bruce Fekrat,

MFA submitted comments to the CFTC in response to its request for comments on its proposed rule on Federal Speculative Position Limits for Referenced Energy Contracts and Associated Regulations. MFA is concerned that the CFTCs proposal will not reduce price volatility or prevent market manipulation, but rather, will hinder commercial risk management. MFA is also concerned that the proposal will reduce liquidity in U.S. futures markets and reduce the competitiveness of U.S. markets. MFA urges the Commission to consider the availability of alternative approaches, such as implementing aggregate position accountability levels, requiring more comprehensive reporting of positions by traders in all related trading venues, publishing more information about hedger and swap dealer positions in OTC and exchange markets, and using additional resources to expand its current monitoring and enforcement programs.