To: Dan3 who wrote (75631 ) 3/5/2008 9:47:34 AM From: Elroy Jetson Respond to of 116555 DBA will be limited in it's ability to push up commodity prices going forward.indexuniverse.com DBA Is Full-Up Matthew Hougan - Tuesday, 04 March 2008 - Index Universe The DBA fund-which invests in commodity futures contracts-has reached its position limits in some of its commodities. The commodity exchanges and the Commodity Futures Trading Commission set maximum amounts that certain investors can hold in individual commodities. DBA's assets have soared recently, adding nearly $1 billion in assets in February alone (to hit $2.8 billion), and that asset growth has pushed the fund against CFTC position limits. As a result, as PowerShares DB said in this filing with the SEC, DBA has started trying to replicate the returns of the index by investing in futures that are similar ... but not identical ... to those in the index itself. DBA has started buying contracts with different expiration dates. For instance, the index tracks the performance of the corn futures contract expiring in December 2008. But the fund includes both that contract and a separate contract expiring in July 2008. Historically, those two have tracked very close to one another, but of course, that doesn't have to be the case. The second thing the fund has done is buy contracts on different exchanges. In the wheat markets, the fund has diversified beyond Chicago wheat contracts to buy contracts in both Kansas City and Minneapolis. But these contracts don't just trade on different exchanges, they are actually different kinds of wheat: Soft Red Winter Wheat (Chicago), Hard Red Winter Wheat (Kansas City) and Hard Red Spring Wheat (Minneapolis). These different varieties tend to perform in similar ways, but not always. They serve different kinds of markets and, because the harvests come due at different times, they can be impacted by different seasonal and weather patterns. Minneapolis wheat, for instance, has seen extraordinary gains recently due to near-term crop shortages. Finally, the index has diversified into alternate or "derivative" contracts for soybeans, buying not just the beans themselves but soybean meal as well. These two products are related, but of course, they do not track perfectly. This does raise some concerns. Deutsche Bank, for instance, claims that the underlying index is designed to pick the most profitable contracts for each commodity based on the expected roll yield. Simple logic, then, suggests that alternate contracts could be suboptimal. And the addition of different types of contracts raises some tracking risk against the index. The CFTC is reconsidering the limits it places on investors, and may increase them in the future. If they don't, we may see more funds adopt the model of DBA and using alternate contracts to try to approximate the returns of the index itself. .