Tag: Position limits

CFTC pushes position limits to new Administration, but finalizes aggregation rules

Today, in a move on its long-pending proposals, the CFTC: (1) re-proposed its new speculative position limits rules (the “Re-Proposal”), which would impose federal limits on 25 physical commodity futures contracts and their “economically equivalent” futures, options, and swaps; and (2) separately issued final rules relating to position aggregation requirements (the “Final Aggregation Rules”). We … Continue Reading

CFTC proposes enhanced Exchange authority over exemptions to proposed position limits

The CFTC has issued a supplemental proposed rulemaking (the “2016 Supplement”) that would give futures exchanges (“Exchanges”) greater authority over exemptions if the CFTC finalizes its long-pending proposed new speculative position limits that it published in December 2013 (the “Limits Proposal”).  In an effort to be responsive to severe criticism of the Limits Proposal, particularly … Continue Reading

ICE Futures US adopts new position limit disaggregation rule for owned entities

ICE Futures US (“ICE”) adopted a new rule, effective March 18, 2016, that provides relief from position limit aggregation requirements applicable to “owned entities.” Specifically, the rule amendment permits certain affiliated entities to disaggregate their positions for purposes of compliance with ICE’s position limits. Background ICE imposes spot-month position limits on all its futures contracts, … Continue Reading

CFTC issues new position limits proposal to make it easier for majority-owned affiliates (greater than 50% to 100% ownership) to disaggregate futures and swaps positions

On September 22, 2015, the CFTC issued a “supplemental” proposed rulemaking (the “2015 Proposal”) to revise its long-pending proposal on aggregation for position limit purposes published in November 2013 (the “2013 Proposal”). The 2015 Proposal, if finalized, would provide companies with over 50% ownership or equity interest in affiliated entities with an easier mechanism to … Continue Reading
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