Date: April 25, 2014
Issue: Derivatives
To: CFTC
Filing Type: CFTC
Description: The undersigned organizations urge the Commission, as a sensible and orderly next step in the rulemaking process, to determine current estimated deliverable supply for each of the 28 physical commodities covered by the proposal. We know that many of the deliverable supply estimates in force for these commodities are greatly out of date. For example, the silver and gold estimates date back to 1983, the natural gas estimate is based on 1996 market data, and corn and soybean estimates rely on 1998 data. The Commission has received updated deliverable supply data from affected contract markets. It has also solicited and received comments on that data.