External Meetings: Meeting w/ICE, Noble, Louis Dreyfus, Cargill

Topic:  ICE and users of the Sugar No. 11 futures contract discussed cash market practices. They commented that the contract should not be subject to federal position limits.  In the alternative, additional transactions should be recognized as bona fide hedging positions, including unfixed price commitments, and such hedging positions should be bona fide through the last trading day.  Regarding anticipatory hedges, their view is the restriction of 12 months applicable to annual production agricultural crops is not appropriate for a crop with multiple harvests over a multiple year life cycle. Further, they requested guidance on a process and timeline for consideration of non-enumerated hedge exemptions and requested CFTC adopt accountability levels in lieu of hard limits.-