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.

Topic:  ICE and users of the Sugar No. 11 futures contract discussed cash market practices.

Topic:  Louis Dreyfus and Noble discussed cash market practices in the cotton market.  Their view is that CFTC should recognize, as a bona fide hedging position, a calendar month spread comprised of long nearby futures and short deferred futures when a commercial merchant has entered into a cash market sale of cotton on call (an unfixed price sales contract), prior to the cash market counterparty fixing the cotton on call price (resulting in a fixed price sales contract).

Topic:  NCFC and member cooperatives discussed their comment letter # 59613 regarding Position Limits for Derivatives, including cash basis sales and bona fide hedges, reporting requirements for bona fide hedges, and parity for non-spot month position limits for wheat futures contracts.

Reporting of all swaps; harmonizing end-user exception with EU

Data acquisition; blocks

Determining transaction sizes for blocks

Data standardization; USIs; UPIs

Phased-in approach; liquidity issues; blocks

RTPR and block sizes and delays