On November 4, CME Group issued Market Regulation Advisory Notice RA1518-5 (Notice) to provide regulatory guidance to market participants concerning CME Group Exchanges’ rules on position limits and exemptions, and position accountability. The Notice also provides interpretative guidance related to each Exchange’s position limit, position accountability and reportable level table in the Interpretations section at the end of chapter 5 of each Exchange’s rulebook.

The Notice addresses questions regarding: (1) differences among position limits, accountability and reportable levels; (2) differences among spot-month, second spot-month, single month and all months for purposes of position limits and position accountability levels; (3) limits for holding delivery instruments; (4) the impact of deliveries in the spot month for purposes of compliance with spot month position limits; (5) aggregation; (6) how to count options on futures for purposes of position limits; (7) diminishing balance contracts; (8) exemptions from position limits; (9) intraday effectiveness of position limits; (10) positions established as a result of trading at settlement, trading at marker or basis trade at index close; (11) orders that have been placed but not executed; and (12) situations where clients or market participants exceed a limit.

The Notice is available here.