External Meetings: Meeting with Commercial Energy Working Group

External Meetings: Meeting with Commercial Energy Working Group

DIscussed the June 2016 Supplemnental NPRM and the December 2013 NPRM, including definitions (including bona fide hedge definition), reporting (including filing date), treatment of commercial transactions under the proposal, application requirements, requirement that the exchange publically posts a generic summary, FOIA protection and request for guidance

External Meetings: Meeting with National Grain and Feed Association

External Meetings: Meeting with National Grain and Feed Association

We discussed the position limtis rulemaking and supplemental notice, including the definition of bona fide hedging, non-enumerated bona fide hedges, the 5-day rule, whether there should be time restrictions on anticipated production hedges, the meaning of a commercially reasonable time period to come into compliance in the context of a CFTC reversal of an exchange determination, the setting of exchange and federal limit levels, and cross commodity hedging,