Commodity Futures Trading Commissioner J. Christopher Giancarlo urged the Commission to consider all costs and benefits in developing new position limits and aggregation requirements and to rely on data to determine whether particular position limits are “necessary or appropriate.” According to Mr. Giancarlo, in a speech given before the Annual Capital Link Global Commodities, Energy & Shipping Form in New York City last week, “I am very concerned that the overall effect of the CFTC’s position limit framework is to impose a federal regulatory edict in place of business judgment in the course of everyday business risk hedging activity.” Separately, in a speech before the ISDA North America conference last week, CFTC Commissioner Sharon Bowen urged the Commission to impose “reasonable ground rules” on algorithmic traders. Requirements would include that algorithmic traders implement “sufficient risk controls.” These would encompass pre-trade risk controls and “processes for immediately disconnecting any algorithm from the market when needed,” said Ms. Bowen. In addition, Ms. Bowen suggested that rules be adopted that “foster increased communication” internally and with exchanges when an algorithm malfunctions and that market transparency regarding algorithmic trading be increased. She specifically asked that exchanges be required to identify the percentage of trades involving one algorithmic trader trading with itself (so-called “self-trades”).