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MANAGED FuNDs AsSOCIATION 

R:CORDS SECTIO 

December 21, 2007 r·_. 

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- I Via Electronic Mail: secretary@cftc.gov 

-- ·' J Attention: Office of the Secretariat 

Commodity Futures Trading Commission · 

Three Lafayette Centre 

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1 15 5 21st Street, N. W. COMMENT r•: ·-I t;; 

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Washington, D.C. 20581 . 

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Re: Proposed Revision of Federal Speculative Position Limits 

Ladies and Gentlemen: 

Managed Funds Association ("MFA") appreciates the opportunity to make this 

submission of comments to the Commodity Futures Trading Commission ("CFTC" or the 

"Commission") on its proposal to revise the speculative position limits for certain 

agricultural commodities set out in Commission Regulation 150.2 ("Federal speculative 

position limits"). MFA and its members have long been interested in CFTC market 

regulation activities, and specifically, Federal speculative position limits. 

MFA is the voice of the global alternative investment industry. Its members 

include professionals in hedge funds, funds of funds and managed futures funds. 

Established in 1991, MFA is the primary source of information for policymakers and the 

media and the leading advocate for sound business practices and industry growth. MFA 

members represent the vast majority of the largest hedge fund groups in the world who 

manage a substantial portion of the approximately $2 trillion invested in absolute return 

strategies. MFA is headquartered in Washington, D.C., with an office in New York. 

Comments 

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We commend the Commission for its proposal to increase the Federal speculative 

position limits for single-month (not including the spot month) and all-months-combined 

positions in all commodities except Chicago Board of Trade Oats contracts and to 

aggregate traders' positions in Regulation 150.2 enumerated commodities across multiple 

designated contract markets ("DCMs") when multiple DCMs list for trading futures 

contracts that share substantially identical terms for determining compliance with Federal 

speculative position limits ("Proposal"). We believe that raising the current position limit 

levels would permit advisors greater flexibility in determining the appropriate positions 

for the accounts that they manage based on their assessment of profit or risk management 

opportunities. We note that the Proposal also recognizes the changing characteristics of 

markets which can allow larger positions to be taken without an adverse impact on price 

2025 M Street, N.W. Suite 800 Washington, DC 20036-3309 Tel: 202.367.1140 Fax: 202.367.2140 

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Office of the Secretariat 

December 21, 2007 

Page 2 of2 

discovery. We strongly support the Commission's effort in this regard. MFA encourages 

the Commission to continue to monitor the appropriateness of the Federal speculative 

position limits and modify them in the future as warranted. 

* * * 

We appreciate this opportunity to comment on the Proposals, and would be 

pleased to meet with you to discuss our comments further. Please feel free to call me or 

Alicia Lewis at (202) 367-1140. 

Sincerely, 

John G. Gaine 

President