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Fact Sheet
CMC1300 L Street, NW, Suite 1020, Washington, DC 20005 | PH: 202.842.0400 | FAX: 202.789.7223
Twitter: CommodityMkts | Blog: www.commoditymkts.wordpress.com | Website: www.commoditymkts.org
EXCHANGE MEMBERSBM&FBOVESPA
Bursa Malaysia Derivatives Berhad
Chicago Board of Trade
Chicago Mercantile Exchange
ICE Futures U.S.
Kansas City Board of Trade
Minneapolis Grain Exchange
New York Mercantile Exchange
INDUSTRY MEMBERSABN AMRO Clearing Chicago, LLC
AGL Resources
Archer Daniels Midland
Avena Nordic Grain
BP Corporation North America
BNSF Railway
Brooks Grain, LLC
Brophy Commodities
Bunge
Cargill Inc.
Cereal Food Processors
CTC Trading Group, LLC
Farms Technology, LLC
FCStone, LLC
Futures International, LLC
FXDD
Gator Trading Partners, LLC
Gavilon, LLC
Gresham Investment Management, LLC
Icarus Trading, LLC
Infinium Capital Management
JP Morgan Futures & Options
Kraft Foods
Laymac, Inc.
Lincoln Grain Exchange
Louis Dreyfus Commodities
Macquarie Bank Limited
Mercuria Energy Trading
McNamara Options, LLC
Mocek, Greg
Rand Financial Services, Inc.
RJ O’Brien
Riverland Ag
Rosenthal Collins Group, LLC
The Andersons, Inc.
The Scoular Co.
Vermillion Asset Management
Virtu Financial, LLC
BOARD OF DIRECTORSCharles Carey, Chairman, CME Group
Matt Jansen, Vice-Chairman, ADM
Marta Alves, BM&FBOVESPA
Mark Bagan, Minneapolis Grain Exchange
Jack Bienkowski, Kraft Foods
Jeff Borchardt, Kansas City Board of Trade
Kyle Boris, CTC Trading Group, LLC
Eric Bowles, Macquarie
Tom Erickson, Bunge
Tom Farley, ICE Futures U.S.
Rich Feltes, RJ O’Brien
Kevin Kaufman, BNSF Railway
Sree Kumar, Bursa Malaysia Derivatives Berhad
Chris LaRosa, CME Group
Jim Layton, Laymac, Inc.
Dave Lehman, Chicago Board of Trade
Dave Lyons, Louis Dreyfus Commodities
Joni Malpede, Rand Financial Services, Inc.
Andy Milnes, BP Corporation
Eric Perry, The Scoular Company
Mike Ricks, Cargill
Gene Rozgonyi, AGL Resources
Dennis Stieren, Gavilon, LLC
Brian Zboril, Infinium Capital Management
OUR MISSIONCMC advocates open, competitive commerce by combining the expertise, knowledge and resources of its members to develo p and support market-based policy.
ACTION ORIENTEDWe are not only your eyes and ears inside the Beltway, but we’re your hands and feet, as well. CMC members and staff spend time meeting face-to-face with legislators and regulators who are writing laws and rules that will impact your business. We are writing letters, submitting comments, and making phone calls that represent your views and concerns. Who we are is what we do.
MESSAGE MULTIPLYINGCMC works with other trade associations and industry organizations to build coalitions to advance our mission and benefit our members. One voice can certainly communicate a message, but the combined voices of CMC’s membership and coalition partners bring not only volume, but diversity of perspective while preserving agreement and clarity of message. CMC is a go-to organization for Congressional and regulatory staff: they know we bring the message from the unique partnership of commodity futures exchanges and their industry counterparts.
NETWORKINGCMC’s State of the Industry annual meeting and other events throughout the year provide valuable opportunities for networking with leaders in the risk management industry.
SIZED FOR SUCCESSCMC is small enough to be responsive to individual member needs and concerns, but large enough To have the influence to get our agenda accomplished.
CMC1300 L Street, NW, Suite 1020, Washington, DC 20005 | PH: 202.842.0400 | FAX: 202.789.7223
Twitter: CommodityMkts | Blog: www.commoditymkts.wordpress.com | Website: www.commoditymkts.org
CONGRESS · House and Senate Ag Committees
· House and Senate Banking Committees
· House Oversight and Government Reform Committee
· Leadership Offices
· Personal Offices and Committee Staffers
· Former Members and Staff
REGULATORY AGENCIES · European Commission
· European Parliament
· Federal Reserve
· International Organization of Securities Commissions (IOSCO)
· United States Commodity Futures Trading Commission (CFTC)
· United States Department of Agriculture (USDA)
· United States Securities and Exchange Commission (SEC)
· United States Treasury
INDUSTRY ORGANIZATIONS · Alliance for Agricultural Growth and Competitiveness (AAGC)
· Coalition for Derivatives End-Users
· Commodity Options and Agricultural Swaps Working Group
· Energy Working Group (EWG)
· International Institute of Finance (IIF)
· Regulatory Improvement Council (RIC)
· Trade Association Liaison Council (TALC)
· US Chamber of Commerce
· Financial Industry Trade Associations
· Agricultural Sector Trade Associations
· Foreign Embassies in Washington
· Financial Industry Consulting Firms
· Law Firms
· Former Senior Public Officials
CMC1300 L Street, NW, Suite 1020, Washington, DC 20005 | PH: 202.842.0400 | FAX: 202.789.7223
Twitter: CommodityMkts | Blog: www.commoditymkts.wordpress.com | Website: www.commoditymkts.org
CMC1300 L Street, NW, Suite 1020, Washington, DC 20005 | PH: 202.842.0400 | FAX: 202.789.7223
Twitter: CommodityMkts | Blog: www.commoditymkts.wordpress.com | Website: www.commoditymkts.org
Market Manipulation: CMC commented to the CFTC on a scienter requirement, the need for clarity on what constitutes manipulation, and the price manipulation test.
End User Exception: CMC commented to the CFTC that a broad end user exception from mandatory clearing of swaps is necessary and beneficial for the industry and consumers.
Position Limits for Derivatives: CMC commented to the CFTC that the proposed position limits are inconsistent with the CEA, the Commission’s aggregation policy is flawed, and the bona-fide hedge exemption is too narrow.
Commodity Options and Ag Swaps: CMC commented to the CFTC on the necessity for harmonious treatment of ag swaps, and on the reasons to not treat forward contracts with embedded options and certain cash transaction bookouts as swaps.
Joint Supplemental Letter on Bona Fide Hedging: CMC and the Energy Working Group commented to the CFTC requesting the Commission to broaden the bona fide hedging definition and opining that compliance with the daily reporting requirement would be burdensome.
Transition Exemption for Options on Ag Commodities: As part of the Commodity Options and Agricultural Swaps Working Group, CMC commented to the CFTC that the Commission should take action immediately to ensure there are no interruptions in the ability of market participants to continue to enter into risk management transactions.
Coalition Letter on Swap Data Reporting: As part of the Coalition for Derivatives End Users, CMC commented to the CFTC that there are aspects of the proposed rule, such as timing and data requirements, that will result in unnecessary burdens to end-users.
Working Group Letter on Portfolio Hedging: CMC and the Energy Working Group commented to the CFTC that the Commission’s proposed rules must properly account for portfolio and dynamic hedging.
Tape Recording Requirements: CMC commented to the CFTC that the Commission should reconsider the substantial costs and limited benefits of imposing the recording requirement.
Margin Requirements: CMC commented to the Prudential Regulators and CFTC that the proposed rule must be modified to allow the use of noncash collateral by nonfinancial end users, and that the rule reduces the international competitiveness of American firms.
Working Group Letter on Inter-Affiliates Swaps: CMC and the Energy Working Group commented to the CFTC to highlight issues pertaining to inter-affiliate transactions that could have a substantial impact on commercial firms in energy and agriculture markets and on swap markets as a whole.
Disruptive Trading Practices: CMC commented to the CFTC saying that the statutory language is too broad, more clarity is needed, and that only intentional conduct should be proscribed.
JANUARY 2011
FEBRUARY 2011
AUGUST 2011
APRIL 2011
JUNE 2011
JULY 2011
MARCH 2011
MAY 2011
COMMENT LETTER TIMELINE
CMC1300 L Street, NW, Suite 1020, Washington, DC 20005 | PH: 202.842.0400 | FAX: 202.789.7223
Twitter: CommodityMkts | Blog: www.commoditymkts.wordpress.com | Website: www.commoditymkts.org
This information will be used by the Commodity Markets Council (CMC) to distribute our weekly
e-letter, send information regarding upcoming meetings and events, and membership communications.
Company: _________________________________________________________________________________________________
Address:___________________________________________________________________________________________________
City:_________________________________________ State: _______________ Zip Code: __________________________
Telephone:______________________________________________ Fax:______________________________________________
E-mail: ______________________________________________________________________________________________________
Representatives in CMC activities will be (please include email addresses):
____________________________________________________________________________________________________________
____________________________________________________________________________________________________________
____________________________________________________________________________________________________________
Membership Options
Please select from the following membership options:
Industry Member (must be actively involved in the sale, marketing, procession, transporting or delivery
of commodities; providing lending; trading of commodity-based derivatives; or other related activity):
q Small (net worth up to $100 million) $6000
q Medium (net worth $100 million - $1 billion) $10,000
q Large (net worth in excess of $1 billion) $18,000
q International Exchange $20,000
Signed: _______________________________________________________________________________________________
Title: ______________________________________________________________ Date: __________________________
Primary Contact Information