The Commodity Futures Trading Commission, by a 3-2 vote on October 15, 2020, adopted amendments to Part 150 of the CFTC Regulations (Amendments). Part 150 currently imposes federal speculative position limits on nine futures contracts as well as options on such futures contracts (collectively, legacy agricultural contracts), and requires exchange position limits on those and other contracts. The most significant aspects of the Amendments include the establishment of new and amended federal position limits for 25 physical commodity derivatives contracts (which may include swaps) and the overhaul of certain exemptions from the position limits and the process to enable a market participant to rely on such an exemption.