Multiple speakers – including Commissioner J. Christopher Giancarlo of the Commodity Futures Trading Commission — called for a phased roll-out of any new position limits adopted by the CFTC during a public meeting of the agency’s Energy and Environmental Markets Advisory Committee held last week. The CFTC proposed new rules regarding position limits on 28 commodities and aggregation in November 2013. (Click here for details in the article “CFTC Proposes New Position Limit Rules: Addresses Absolute Limits of 28 Core Futures Products, Aggregation, and Bona Fide Hedging” in the November 5, 2013 edition of Between Bridges.) According to Commissioner Giancarlo, “proceeding in a phased approach would give all market participants the opportunity to adjust to the new process of tracking and reporting commodity swaps along with their futures and options. A phased approach would also be useful for the CFTC, which will then have additional time to obtain better data about the OTC market for physical commodities, as well as conduct additional research and analysis to determine whether federal position limits are appropriate and necessary at all outside of the spot month.” William McCoy, speaking on behalf of the Futures Industry Association, also argued that a phased approach could help mitigate against “unintended consequences.” Stephen Berger, speaking for the Managed Futures Association, said that the CFTC should adopt a two-phase approach in rolling out any new position limits. The first phase would include adopting spot month limits only; adopting a definition for a bona fide hedge position; and relying on and reviewing data from exchanges’ position accountability levels for non-spot months. The second phase would include the adoption of accountability levels for non-spot months based upon data gathered during the first phase. Ron Oppenheimer, on behalf of The Commercial Energy Working Group, argued that non-enumerated hedging exemptions should be granted by exchanges and not the CFTC (as proposed) because of the “depth and breadth” of exchanges’ experience in evaluating hedging strategies and exchanges’ “current oversight of market participant positions, particularly in the front month.”