CFTC No-Action on Aggregation Requirements for Futures and Swaps

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On July 24, the CFTC announced temporary no-action relief to facilitate its coordination of the May 30 Notice of Proposed Rulemaking on aggregation with the implementation of positions limits under Part 151 of the Commodity Exchange Act. The relief provides two methods for compliance: (i) as if the positions limits rule were amended to include the provisions proposed in the aggregation notice and (ii) in conformity with the disaggregation criteria specified in the no-action relief. The relief is time-limited to no later than December 31. CFTC Release.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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