Date: April 3, 2014
Issue: Commodities
To: Federal Reserve
Filing Type: Regulator
Description: The implementation of commodity market regulations under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act created a number of new regulatory challenges that affect the pricing and complexity of hedging instruments which commercial businesses rely on to run their operations efficiently and safely. We urge the Federal Reserve to not take steps that would compound these challenges, by directly or indirectly forcing well-capitalized, well-regulated FHC counterparties out of the physical commodities markets.