Block size tests

Topic:  Cargill discussed certain derivative risk management activity associated with cash market bids or offers.

Cargill representatives discussed the pending position limits rule, including issues concerning anticipatory hedging.  They explained that by the nature of their business they often made firm bids and offers, and they gave reasons why these offers were in the nature of hedging and risk management of physical supplies.  Such irrevocable offers should not count against any speculative limit, for they do carry risk and can and should be hedged.  Otherwise, Cargill be competitively disadvantaged compared to others for spec limit purposes, given that their business model requires

Topic:  Bona fide hedging

CFTC Aggregation Release and PEGCC comment letter

CFTC staff and representatives of the Futures Industry Association (FIA) had a meeting regarding the CFTC’s Customer Protection rulemaking and the Regulation 1.20 template acknowledgment letter.

The meeting discussed substituted compliance determinations, the treatment of US branches of foreign banks and foreign branches of US banks, and the interpretation of the term "US person" as applied to collective investment vehicles.

Telephone call to discuss CFTC’s Customer Protection rulemaking proposal and the Regulation 1.20 template acknowledgment letter.

Telephone call to discuss Customer Protection rulemaking proposal.