March 17, 2009
Mr. Andrei Kirilenko
Office of the Chief Economist
U.S. Commodity Futures Trading Commission
1155 21st Street, NW
Washington, DC 20581
Submitted via email to: akirilenko@cftc.gov
Dear Mr. Kirilenko:
The North American Millers' Association (NAMA) is the trade association representing the wheat, corn, oat and rye milling industry. NAMA’s 47 member companies operate 170 mills in 38 states and Canada. Their aggregate production of more than 160 million pounds per day is approximately 95 percent of the total industry capacity.
Millers have been classic hedgers since the creation of futures markets in the mid 1800’s. Also, US millers buy more US cash wheat than all other buyers combined. We were interested, therefore, to learn that CFTC is creating a Subcommittee on Convergence in Agricultural Commodity Markets.
NAMA strongly believes the millers’ interests should be represented on the subcommittee. I have been a member of the CFTC Agricultural Advisory Committee for years. However, on this highly technical matter I would like to defer to the knowledge of a futures market expert. Therefore, NAMA nominates Mr. Rick Cole as a subcommittee member.
Mr. Cole has more than 30 years’ experience executing futures contracts as a grain buyer for General Mills, Inc. GMI is the world’s largest flour buyer, but is also the US’ sixth largest flour miller, producing more than seven million pounds of flour each day. We believe Mr. Cole would be a tremendous asset to the subcommittee’s deliberations. As both a buyer and seller of grain and milled grain products, he is knowledgeable with both sides of futures contracts.
We believe the subcommittee would be lacking if the milling industry is not represented, and give Rick Cole our strongest recommendation. Thank you for your consideration.
Sincerely,
James A. Bair
Vice President
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