The AFR Education Fund wrote a letter to the Commodity Futures Trading Commission regarding its proposed new “Electronic Trading Risk Principles”. The letter faulted the principles-based approach as basically allowing Wall Street to regulate itself in this important area. A copy of the letter can
The AFR Education Fund sent this letter to the Commodity Futures Trading Commission opposing new rules that would be ineffective in preventing speculation in energy and agricultural commodities. A pdf of the comment can be downloaded here: AFR Education Fund Comment on Position Limits Proposal
“AFR strongly supports measures to both limit and control risks of physical commodity involvement at financial holding companies. …Specifically, we support the new consolidated limits on the total size of commodity holdings, the capital increase to 300 percent risk weights applied to commodities held under 4(k), and more…”
“By freezing the CFTC’s funding at its current inadequate level for the next five years, this legislation exacerbates the agency’s most fundamental problem – a lack of resources to accomplish its mission. After the 2008 financial crisis, the CFTC became newly responsible for hundreds of trillions of dollars in previously unregulated swaps markets. …Even as it fails to address the pressing problem of funding, HR 238 would also load down the CFTC with additional mandates that would drain resources and act as a roadblock to necessary oversight and enforcement.
We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.
In an Oct. 23 letter, AFR urged the Securities and Exchange Commission not to to approve the organization and marketing of a commodity Exchange Traded Fund based on the storage of physical copper. Allowing speculators to hoard this vital industrial metal would damage the economy and set a dangerous precedent, the letter warned.
“The last time we saw this speculative feeding frenzy was in 2008, when in July, amidst the meltdown in the credit and housing markets, speculators wildly ran up the price of crude oil to over $140 per barrel. Was the steroidal price explosion in 2008 due to increased demand or a significant reduction in supply? Trading volume was nearly 15 times world oil demand that year, according to research compiled by Americans for Financial Reform.”
Dr. Mark Cooper, CFA Director of Research, submitted the following statement for the record of the hearing on Excessive Speculation and Compliance with the Dodd-Frank Act, being conducted by the Senate Committee on Homeland Security and Governmental Affairs, along with CFA’s recent report entitled Excessive Speculation and Oil Price Shock Recessions: A Case of Wall Street ‘Déjà vu All Over Again.’
Economists Support Regulation of Commodities Futures Markets in the Reconciliation of the Financial Reform Bill
June 10, 2010 RE: Regulation of Commodities Futures Markets in the Reconciliation of the Financial Reform Bill Dear Members of the Reconciliation Committee conference: As you are well aware, in the momentous work ahead of you in reconciling the House and Senate versions of the
JOINT STATEMENT OF SHARED PRINCIPLES FOR NEEDED REFORMS IN THE FUTURES/DERIVATIVES MARKETS AS REVISED AND AGREED TO AT THE JOINT MEETING OF MEMBERS OF THE COMMODITY MARKETS OVERSIGHT COALITION AND THE AMERICANS FOR FINANCIAL REFORM January 7th, 2010 Members of the Commodity Markets Oversight Coalition