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Commodities Futures Trading Commission › Position Limits

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
Dechert LLP

CFTC Adopts New Federal Position Limits and Amendments

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The Commodity Futures Trading Commission, by a 3-2 vote on October 15, 2020, adopted amendments to Part 150 of the CFTC Regulations (Amendments). Part 150 currently imposes federal speculative position limits on nine futures...more

K&L Gates LLP

Know Your Limits: The CFTC Adopts Position Limits for Derivatives Related to Energy, Agriculture, and Metals Products

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INTRODUCTION - The Commodity Futures Trading Commission (CFTC) recently voted 3–2, along party lines, to approve a final rule (Final Rule) regarding position limits for certain futures contracts and economically equivalent...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Finalizes Position Limits Rules

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On October 15, 2020, the Commodity Futures Trading Commission (CFTC) voted 3-2 to adopt new rules on speculative position limits (the Final Rule). The Final Rule will become effective 60 days after publication in the Federal...more

Katten Muchin Rosenman LLP

CFTC Adopts New Position Limits Requirements

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On October 15, the Commodity Futures Trading Commission adopted new rules on position limits. The new rules mark an important step forward in a decade-long journey to enact one of the remaining key provisions of Title VII of...more

Morgan Lewis

Latest CFTC Position Limits Proposal: If At First You Don't Succeed, Try, Try Again

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After a decade of rulemaking efforts, the Commodity Futures Trading Commission is proposing revisions to its regulations concerning federal speculative position limits to conform to the Wall Street Transparency and...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes New Rules on Position Limits

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On January 30, 2020, the Commodity Futures Trading Commission (CFTC or Commission) voted 3-2 to issue a proposed rulemaking on speculative position limits (the Proposal). The Proposal would apply spot month-only federal...more

Hogan Lovells

Energy and metals companies and funds beware: Your trading positions may be "limited"

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On 30 January 2020 the Commodity Futures Trading Commission (CFTC) approved on a 3-2 vote proposed rules addressing position limits on speculative derivatives (Position Limits Proposal). The Position Limits Proposal has a...more

Katten Muchin Rosenman LLP

Bridging The Week - January 2020 #3

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Will the fourth time be the charm? This week, the Commodity Futures Trading Commission will try for the fourth time since 2011 to revise its speculative position limits rules. Details have not been made public, but Heath...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Staff Extends Relief With Respect To Certain Position Limit Aggregation Requirements

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Until August 12, 2022, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account controller”...more

A&O Shearman

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

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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...more

Katten Muchin Rosenman LLP

CFTC Finalizes Aggregation Rules and Re-Proposes Position Limits Rule

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On December 5, the Commodity Futures Trading Commission (CFTC) issued final regulations regarding the aggregation of positions and accounts to assess compliance with speculative position limits, as well as to add a potential...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Adopts Amendments to Position Limit Aggregation Rules

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Key Points - - Unless an exemption from aggregation is available, all positions in accounts for which any person controls the trading or holds a 10 percent or greater ownership or equity interest must be aggregated...more

Katten Muchin Rosenman LLP

Bridging the Week - December 2016 #2

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Last week, the Commodity Futures Trading Commission proposed revised position limit rules and finalized requirements related to the aggregation of positions and accounts to assess compliance with speculative position limits...more

A&O Shearman

US Commodity Futures Trading Commission Issues Supplement Modifying Position Limits Proposal

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The CFTC issued for public comment a supplement to the CFTC’s December 2013 position limits proposal. The supplement would permit exchanges to recognize, subject to CFTC review, certain positions in commodity derivative...more

Katten Muchin Rosenman LLP

CFTC Proposes To Allow Designated Contract Markets and Swap Execution Facilities To Recognize Certain Hedging and Spread Positions...

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On May 26, the Commodity Futures Trading Commission (CFTC) proposed amendments to its previously proposed rules related to speculative position limits on 28 core referenced futures contracts (the "2016 Amendment"). If...more

Cadwalader, Wickersham & Taft LLP

CFTC Unanimously Approves Supplemental Proposal on Position Limits

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On May 26, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved a proposed supplement (“Supplemental Proposal”) to its December 2013 proposal to establish position limits on futures and economically...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Eliminates End-User Trade Option Reporting Requirements and Addresses Applicability of Position Limits"

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The Commodity Futures Trading Commission (CFTC or Commission) adopted a final rule effective March 21, 2016, that eliminates the reporting and recordkeeping requirements under the CFTC’s existing trade option exemption for...more

Cadwalader, Wickersham & Taft LLP

CFTC Adopts Final Trade Option Rule

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On March 16, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved amendments to the rules applicable to certain physically-settled options referred to as “trade options.” This final rule substantially...more

Latham & Watkins LLP

Dodd-Frank Almost 6 Years Later: Where Are We Now? Energy-Related Derivatives Regulation

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In the almost six years since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the US Commodity Futures Trading Commission (CFTC) has, in large part, finalized its rulemakings...more

Katten Muchin Rosenman LLP

Bridging the Week - February 2016 #2

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Two Broker-Dealers to Pay US $154 Million to the State of NY and the SEC to Resolve Allegations of Wrongdoing by Their Dark Pools: Barclays Capital Inc. and Credit Suisse Securities settled allegations by the Securities and...more

WilmerHale

CFTC Updates Position Limits Rule

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On September 22, 2015, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved the publication of a “supplemental” proposed rule on position limits. The supplemental proposal would modify the...more

Latham & Watkins LLP

CFTC FORM 40/40S Reporting Requirements

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Significant amendments to the CFTC’s large trader reporting program will apply as of August 15, 2014. The U.S. Commodity Futures Trading Commission (CFTC) has seemingly increased the number of Form 40/40S requests it...more

Eversheds Sutherland (US) LLP

Legal Alert: CFTC Division of Market Oversight Releases Questions for June 19 Roundtable on Position Limits

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The Commodity Futures Trading Commission (CFTC) will host a public roundtable on June 19, 2014, to discuss questions related to a proposed rulemaking to establish speculative position limits for 28 exempt and agricultural...more

Katten Muchin Rosenman LLP

CFTC Seeks Additional Comments on Position Limits for Physical Commodity Derivatives

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The Commodity Futures Trading Commission is seeking additional comments on its proposed regulations relating to position limits for physical commodity derivatives. The CFTC will accept comments on its proposals regarding...more

Moore & Van Allen PLLC

The Gift That Keeps On Giving: CFTC’s Misaligned Definition of Forward Contracts Gives Rise to Another Potential Burden on LDCs...

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In our recent post, “CFTC Forward vs. Trade Option: LDCs Still Struggle as Trade Option Reporting Deadline Looms,” we discussed the unintended impact of the Dodd-Frank Wall Street Reform and Consumer Protection Act...more

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