Proposed Rule Changes by NYSE Arca, Inc. to List and Trade Shares of the JPM XF Physical Copper Trust (SR-NYSEArca-2012-28) and the iShares Copper Trust (SR-NYSEArca-2012-66)

Abstract

This memorandum provides an empirical analysis conducted by the Staff of the Division of Risk, Strategy, and Financial Innovation (“Staff”) related to the potential effects of NYSE Arca, Inc. proposed rule changes to list and trade shares of the JPM XF Physical Copper Trust (“JPM Copper Trust”) and the iShares Copper Trust.

The Staff’s findings are summarized as follows: The Staff found no clear evidence of statistical causality between the historical flow of assets to physical metals ETPs and underlying commodity prices of those metals. The Staff found that there is not a strong statistical relationship between copper inventories and copper prices.