As a part of the public comment period, CMC submitted a comprehensive letter to the CFTC regarding the end-user and customer issues within the Commission’s proposed position limits rule.  Specific issues discussed included: the definition of bona fide hedging – including anticipatory hedging, portfolio hedging, and gross versus net hedging, the inclusion of trade options within position limits, deliverable supply estimates and the position limit levels, aggregation concerns, and reporting requirements.  Also included with the letter was a list of specific examples of commercial transactions CMC believes to be examples of bona fide hedging transactions.