1.

How does price discovery occur in the metal markets, considering both the cash and derivative markets as well as domestic and international markets?

2.

What is the role of passive, long-only positions such as those associated with index funds or exchange-traded funds in the metals markets and how might their trading activities and potential market impact roles relate to the consideration of position limits?

3.

Could and should speculative position limits be applied consistently across all metals derivatives markets and participants, including index traders and managers of Exchange Traded Funds?

4.

Would such limits enhance market integrity and efficiency?

5.

If the Commission were to establish position limits for metals markets,

a) What formulation should be used to determine position limit levels for each market?

b) What quantitative measures should be used in setting limits on the size of an individual trader’s position?

c) Should limits be established by percentage or proportion of the market or by fixed number of allowed contracts?

d) Should limits apply in all months combined, in individual months, and in the delivery month?

e) Should spread trades be incorporated into a position limit regime?

f) Should the Commission limit the aggregate amount of positions held by one trader across different markets?

g) What metal commodities should be covered?

h) Would speculative position limits be effective in metals markets where the preponderance of trading activity and positions may involve cash market activity or trading overseas?

6.

If the Commission were to establish position limits for metals derivatives markets, what types of exemptions from such limits should be permitted?

a) The statute states exemptions should only be granted to bona fide hedgers. What should be the qualifying factors for an entity to be determined to be a bona fide hedger?

b) In granting exemptions, should the Commission consider the nature of an intermediary’s counterparties (e.g., should the Commission consider “looking through” a swap dealer’s or index trader’s position to its counterparties)?