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External Meetings: Telephone Conversation with Paul Pantano
XXVI. Position Limits
Dan M. Berkovitz
Cadwalader Wickersham & Taft (representing commercial energy and agricultural end users)
Participants discussed the owned-non-financial exemption from the aggregation requirements in the position limits rulemaking. Mr. Pantano urged the Commission to retain the ONFE exemption as proposed and stated that the retention of the Independent Account Controller (IAC) exemption did not provide sufficient relief to commercial firms, and that the Commission had not provided sufficient notice to commenters in the event that it did not retain the proposed ONFE exemption and instead re-instate the IAC exemption.