Corporate and Financial Weekly Digest - Volume XII, Issue 31

CFTC -

CFTC Suspends Need of Formal Notice for Position Disaggregation Relief -

On August 10, the Commodity Futures Trading Commission (the CFTC) issued no-action relief, eliminating the need for certain persons otherwise required to aggregate positions with certain other persons for CFTC position limit purposes to pro-actively file with the CFTC, beginning August 14, formal written notices supporting disaggregation of positions with such other persons relying on the CFTC’s owned-entity exemption, independent account controller exemption and certain other exemptions from aggregation available under CFTC Rule 150.4(b)(1). Upon request by the CFTC or a designated contract market (DCM), however, such persons will have to file such a formal written notice with the CFTC or DCM, as requested, within five business days. However, this is an after-the-fact obligation, not a pro-active obligation. This relief will be in effect through at least August 12, 2019.

Please see full publication below for more information.

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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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