Date: February 10, 2014

Issue: Regulatory Reform, Position Limits

To: Commodity Futures Trading Commission

Filing Type: Regulatory

Description: We believe that the Commission’s failure to consider current, accurate data in issuing the PL Proposal, and the PL Proposal in its current form, would lead to decreased liquidity that is essential to enable market participants to hedge and operate their businesses in an efficient and effective manner. Further, we believe the PL Proposal would impair the efficiency and effectiveness of the U.S. derivatives markets through increased costs to hedgers, which likely would be passed on to consumers.

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