The National Grain and Feed Association has called on the Commodity Futures Trading Commission to clarify and narrow a proposed recordkeeping rule that could require grain elevators, feed mills, grain processors and others to record all communications, including telephone conversations, with farmers and other commercial firms that ultimately result in cash or cash-forward contract transactions. 

The CFTC’s proposal would require records of “all oral and written communication provided or received concerning quotes, solicitations, bids, offers, instructions, trading and prices that lead to the execution of transactions in a commodity interest or cash commodity, whether communicated by telephone, voicemail, facsimile, instant messaging, chat rooms, electronic mail, mobile device or other digital or electronic media.”

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The NGFA has expressed concern that such requirements would be burdensome and costly, as well as create challenges with existing technology systems. “At the least, we urge the agency to adopt a generous timeline and flexible attitude toward implementation for futures commission merchants and introducing brokers, especially smaller firms for which short-term adoption of the proposed standards may pose a significant investment," said the NGFA.