On the other hand, a number of commodities end-users, including corporate treasurers and municipalities, as well as several trade associations and others, argued that financial holding companies provide valuable and hard-to-replace services to end-users. They also argued that financial holding companies are reliable and low-risk counterparties that enhance the efficiency of the commodities markets and provide additional liquidity to those markets.
These commenters contended that financial holding companies can successfully mitigate the risks of commodities activities with robust risk management, insurance, and maintenance of appropriate corporate separateness.