US Commodity Futures Trading Commission Provides Time-Limited No-Action Relief for Aggregation Notice Filings for Position Limits

A&O Shearman
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Shearman & Sterling LLP

The CFTC’s Division of Market Oversight issued a time-limited no-action letter stating that, from February 14, 2017 to August 14, 2017, it will not recommend an enforcement action for failure to file a notice when relying on certain aggregation exemptions from federal position limit levels. Absent this relief, on February 14, 2017, market participants would have been required to file notices to rely on certain aggregation exemptions under CFTC regulation 150.4(c).

DMO also announced the availability of a portal that provides the form and manner for filing aggregation exemption notices. This new portal is available on the Forms & Submissions page of www.cftc.gov.


Although the no-action letter provides temporary relief from the aggregation notice filing compliance date of February 14, 2017, DMO is providing the portal for participants who choose, of their own accord during the relief period, to file a notice with the CFTC of their intent to take advantage of certain aggregation exemptions under CFTC regulation 150.4(c).

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CFTC staff letter.

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