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External Meetings: Meeting w/Noble
Position Limits for Derivatives
Salvatore Penna (Noble)
De'Ana Dow (Capital Counsel)
Noble Americas Corp.
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.