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CFTC Staff Extends Relief With Respect To Certain Position Limit Aggregation Requirements – Commodities/Derivatives/Stock Exchanges


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Key Points:

  • Until August 12, 2025, 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” disaggregation

On August 10, 2022, staff of the U.S. Commodity Futures Trading
Commission (CFTC) issued No-Action Letter 22-09,1 which
provides relief with respect to the position limit disaggregation
notice filing requirements under Rule 150.4(c),2 as well
as certain other interpretive relief. The letter marks the second
extension of all relief originally provided in CFTC No-Action
Letter 17-37 until the earlier of August 12, 2025, and the
effective date of a rulemaking codifying the no-action relief.
Please refer to Akin Gump’s prior client alert for an overview of the
no-action relief.3

Staff noted that while the final position limits rule adopted by
the CFTC at the beginning of 2021 did not amend the existing
position limit aggregation requirements, the final rule will change
the existing scope of federal position limits by, among other
things, subjecting new contract markets and market participants to
federal position limits for the first time. Accordingly, staff
indicated that it intends to use the additional three-year period
of aggregation relief to assess the impact of such relief on the
expanded federal position limits regime and consider whether to
recommend codifying the relief through a formal notice and comment



2 The CFTC’s position limit aggregation rules are
codified under 17 CFR 150.4(c).


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