November 15, 2012
While respecting the District Court's decision, I strongly disagree and our appeal lays out why the mark was missed on this important issue.
Our appeal should also send a message that the largest speculators on the planet can't litigate regulators to death. We will fight back. Your deep pockets can't protect you from what the law clearly states. Consumers will benefit from speculative position limits.
In addition to our appeal, on which I expect we will prevail, we should promulgate yet another rule to provide a belt and suspenders approach to this important issue. That means we also concurrently propose and finalize yet another position limits rule.
Last Updated: November 15, 2012