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NMPF Comments on Dodd-Frank Rules

June 10, 2011

NMPF submitted comments last week to the Commodity Futures Trading Commission (CFTC) on several of the proposed rules and proposed rulemaking originating from the Dodd-Frank Wall Street Reform and Consumer Protection Act, which bans all agricultural futures, options, and swaps that aren’t specifically allowed by the CFTC.

In each of these comments, NMPF urged the Commission to minimize the unnecessary regulation of innovative risk management tools for farmers and cooperatives – particularly agricultural swaps – and to avoid counterproductive interference in cooperative marketing. Agricultural swaps and agricultural producers, processors, and distributors (defined together as ‘end users’ in CFTC rulemaking) did not cause the recent financial crisis, and their hedging does not pose a risk to the financial system.

Comments from farm groups, including NMPF, have already made substantial progress in raising CFTC’s awareness of the needs that agricultural end users have for hedging, and in moving the Commission to broaden exemptions for end users, to state their intention not to regulate transactions within a cooperative association, and to explore greater regulatory exemptions for physical market participants (meaning those engaged in trading physical products directly).

NMPF’s comments can be found at the CFTC’s Dodd-Frank comment site.

NMPF has addressed the following rules, identified by Federal Register reference: 75 FR 59666; 75 FR 65586; 75 FR 67277; 75 FR 80174; 75 FR 80747; and 76 FR 6095.

If you have any questions, please contact Roger Cryan in the NMPF offices.