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GAO-09-285R 1 (2009-01-30)

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T   E  IAccountability * Integrity * Reliability
United States Government Accountability Office
Washington, DC 20548




         January 30, 2009


         The Honorable Collin Peterson
         Chairman
         Committee on Agriculture
         House of Representatives

         Subject: Issues Involving the Use of the Futures Markets to Invest in Commodity
         Indexes

         Until mid-2008, prices for a broad range of physical commodities, from crude oil to
         crops such as wheat, had increased dramatically for several years-raising
         concerns and leading to a debate over the possible causes. Some market
         participants and observers have attributed the price increases to fundamental
         economic factors related to supply and demand. Others have suggested that the
         price increases resulted from speculation in the futures contracts by hedge funds
         and investors in commodity indexes. Like stock indexes, commodity indexes track
         the composite price of a basket of long futures positions in physical commodities.'
         The indexes' investment strategy is passive, remaining the same regardless of
         whether prices are falling, rising, or flat. Two commonly referenced commodity
         indexes are the Standard & Poor's Goldman Sachs Commodity Index (S&P GSCI)
         and Dow Jones-American International Group Commodity Index (DJ-AIGCI), which
         are based on a broad range of physical commodities, including energy products,
         agricultural products, and metals. Since around the mid-2000s, pension plans,
         endowments, and other institutional investors increasingly have used investments
         in commodity indexes to obtain exposure to commodity prices as an asset class,
         typically to diversify their portfolios or hedge inflation risk.2

         Your letter asked us to examine various issues surrounding how commodity-index
         futures trading is addressed by various laws and regulations. Futures exchange
         regulations that can affect such trading include margins, or performance bonds,


         'A futures contract is an agreement to purchase or sell a commodity for delivery in the future. A long
         futures position is one in which the holder has bought a futures contract and is obligated to take
         delivery of the commodity in the future. However, few contracts actually result in delivery, because
         the vast majority of contracts are offset by making an equal but opposite trade before the delivery
         date.
         2Inflation risk is the risk associated with the return from an investment not covering the loss in
         purchasing power caused by inflation.


GAO-09-285R Commodity Indexes

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