The three primary points/asks made in this letter are:

• Primarily should mean Predominately—85% of revenue is derived from trading
• Insert “Financial” in front of assets in the definition of financial end-user definition
• Recognize that Commercials are not trading when using financial assets to hedge commercial risk

http://comments.cftc.gov/PublicComments/ViewComment.aspx?ID=60627&GUID=514b67cf-1821-4cc3-a3eb-df3e3429cf19