Action Alert

Fair trade or free trade? Let your voice be heard on Minnesota’s future!

The Obama Administration is negotiating two new mega trade deals (one with Pacific Rim countries, another with Europe) entirely in secret, with the goal of further expanding the NAFTA-model of free trade. These trade agreements could have major impacts on Minnesota's farmers, workers, small business owners and rural communities. They could limit Minnesota’s ability to support local food and energy systems and grow local businesses. In order to stay up to speed, Minnesota has set up a new Trade Policy Advisory Council (TPAC) to advise the state legislature and Governor.

TPAC wants to hear from Minnesotans: What concerns do you have about free trade? What role could TPAC play in the future? Now is your opportunity to have a say in our future trade policy. Complete the survey and let them know future trade negotiations should be public, not secret. Help ensure the voices of all Minnesotans are heard in the development of trade agreements and that they protect local control and our quality of life. The free trade model has failed for Minnesota and we need a new approach to trade. Help ensure the voices of all Minnesotans are heard before trade agreements are completed, and that they protect local control, our natural resources and our quality of life.

Please take five minutes and complete the survey. To find out more about these trade agreements, go to

Comment in response to petition to the Commodity Futures Trading Commission for exemptive relief regarding “Aggregation, Position Limits for Futures and Swaps,”

By Dr. Steve Suppan   
Published July 18, 2012


IATP is grateful for the opportunity to share its views on questions posed by the Commodity Futures Trading Commission as it considers how to respond to the Commercial Energy Working Group (“Working Group”) petition for an exemption from the Part 151 rule regarding positions limits that requires aggregation of data on positions held in futures, options and swap contracts.[i] As the Commission notes in its position limits rule, “In light of the importance of aggregation standards in an effective position limits regime, it is critical that the Commission effectively and efficiently monitor the extent to which traders rely on any of the disaggregation exemptions.”[ii]  The requested exemption from aggregation would apply to all owned non-financial entities (i.e. entities that own 10 percent or more of a non-financial entity, subject to a demonstration of the independence of control of non-financial entity trading positions), including agricultural ones. IATP is among many analysts and scholars who believe that passively invested energy contract dominant commodity index funds and related instruments disrupt agricultural price formation based on fundamental factors.[iii]

IATP is therefore concerned that effective implementation of CFTC position limit rules to prevent excessive speculation on agricultural commodity contracts will be impeded if the proposed Working Group exemptions from aggregation of trading data are granted. Although the Commission estimates that just ninety entities will be affected by the filing requirements for the proposed amendment to the Position Limits Rules (FR 31781), these entities include the Designated Contract Markets, swaps execution facilities, Foreign Contract Markets, foreign brokers and large traders (FR. 31780). These entities will have the resources to apply for and received the proposed exemptions from aggregation.  

To continue reading, download the entire letter.


[ii] “Position Limits for Futures and Swaps,” Commodity Futures Trading Commission, Federal Register, 76:223 (November 18, 2011), 71679.

[iii] For a bibliography of about a hundred recent academic and non-governmental organization studies on excessive speculation, see

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