CFTC Proposes New Position Limits for Futures, Options, and Swaps and Amended Aggregation Requirements


Introduction -

The U.S. Commodity Futures Trading Commission (“CFTC”) has proposed a comprehensive set of regulations imposing speculative position limits on exchange-traded futures and options contracts and economically equivalent derivatives that reference 28 agricultural, metal, and energy commodities (“Proposed Position Limit Rules”). On the same day, the CFTC proposed amendments to its existing requirements for aggregating positions controlled by a single participant for the purpose of applying the proposed position limits (“Proposed Aggregation Amendments”).

This Dechert OnPoint discusses: (i) the recent history of the CFTC's position limits regime, (ii) the new “Referenced Contracts” to which the position limits would apply and the proposed methodology for determining the position limits, and (iii) the requirements for aggregating positions and the proposed expanded circumstances under which aggregation is not required.

Please see full publication below for more information.

LOADING PDF: If there are any problems, click here to download the file.

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.

© Dechert LLP | Attorney Advertising

Written by:


Dechert LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.