External Meetings: Meeting w/Noble

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.
Position Limits for Derivatives

CFTC Staff
Matthew Hunter

Stephen Sherrod

Riva Adriance

Harold Hild

Christa Lachenmayr
Salvatore Penna (Noble)

De'Ana Dow (Capital Counsel)
Noble Americas Corp.