ICE Contemplates Emergency Position Limits In Cotton After Yet Another Limit Up Lock

You don't go up 28% in one month on free and endless Bernanke Bux without the ICE slapping your hand. Sure enough:

ICE Futures U.S.®, Inc. (“Exchange”) is contemplating taking the following action effective with the March 2011 Cotton No. 2® futures contract. Cotton market participants who expect to carry positions in excess of the spot month position limit, 300  contracts, into the notice period would be required to file an exemption request form with the Market Surveillance Department. To be eligible for a notice period exemption under Exchange Rule 6.26 (Hedge Exemption), applicants would request a specific long or short position sufficient to cover the applicant’s bona fide hedging requirements for the contract month’s delivery month and the  next succeeding calendar month.

Information would be provided to demonstrate that the requested position limit was economically appropriate to the reduction of risks arising from the potential change in the value of the assets owned by the applicant such as inventories and fixed price physical purchases or liabilities owed such as fixed price physical sales.

An exemption request would have to be approved by the Exchange in order for a market participant to carry a Cotton No. 2® futures position in excess of the 300 contract spot month speculative position limit into the Notice Period. Pursuant to Rule 6.26, exemption requests would have to be received by the Exchange no later than five (5) business days prior to the first notice day of the contract month. Thus, exemption requests for the March 2011 notice period would have to be submitted by February 14,  2011. Any exemptions granted would be for a specified contract month only and should not be viewed as relief from the responsibilities all traders have to transact their business in a manner consistent with an orderly market.

Exemption request forms may be obtained by contacting the Market Surveillance Department (212-748-4031 or


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