1400 Crystal Drive, Suite 260
Arlington, VA 22202
(202) 289-0873
ngfa.org
May 21, 2025
The Honorable Caroline Pham
Chairman
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street NW
Washington, DC 20581
Subject: Request for Comment on Trading and Clearing of Derivatives on a 24/7
Basis
Dear Ms. Pham:
The National Grain and Feed Association (NGFA) appreciates the opportunity to comment
on the above referenced request for comments.
NGFA, established in 1896, consists of grain, feed, processing, exporting and other grain-
related companies that operate facilities handling U.S. grains and oilseeds. Its membership
includes country and export grain elevators; feed and feed ingredient manufacturers;
biofuels companies; grain and oilseed processors and millers; exporters; livestock and
poultry integrators; and associated firms that provide goods and services to the nation’s
grain, feed and processing industry.
NGFA members are commercial hedgers that use futures contracts to manage price risk
related to the commodities they buy or sell. They do this to reduce the impact of fluctuating
prices on their bottom line, essentially locking in a price for the future to help budget and
control expenses. We believe expanding trading hours to 24/7 would increase price risk
and costs without significant benefit.
NGFA members are opposed to expanding the current futures exchange trading hours for
agricultural commodities for the following reasons:
1. Spreading liquidity across a wider trading timeframe would create unnecessary
volatility, potentially widen bid/ask spreads, and expand potential for market
manipulation.
2. The underlying cash market does not trade 24/7, thus having futures markets open
for more hours while cash markets are closed would create additional exposure and
risk for our members.
3. Our members perform their daily reconciliation functions when markets are closed.
This function is critical in managing risk and exposure in cash markets.
4. A pause in trading in futures markets is essential for physical deliveries. This pause
allows those involved in physical deliveries to assess what is changing in cash
markets as well as in futures markets and ultimately their delivery economics.