Law School Toolbox Podcast Episode 263: Listen and Learn -- Subject Matter Jurisdiction
The Commodity Futures Trading Commission ("CFTC") Division of Market Oversight ("DMO") has issued relief (see CFTC Letter 21-21) extending the no-action positions previously granted with respect to certain position...more
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...more
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
CFTC Staff Issues Interpretive Guidance Regarding Exemption from Aggregation - On May 2, 2018, the Commodity Futures Trading Commission's ("CFTC") Division of Market Oversight issued a CFTC staff letter with interpretive...more
On May 2, 2018, the Commodity Futures Trading Commission’s (“CFTC“) Division of Market Oversight issued a CFTC staff letter with interpretive guidance regarding CFTC Regulation 150.4(b)(1), an exemption from position...more
The Commodity Futures Trading Commission voted unanimously to repropose regulations implementing limits on speculative futures and swaps positions as called for in the Dodd-Frank Act. In a separate vote, the CFTC approved...more
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
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
On December 5, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule amending the requirements to aggregate positions subject to a CFTC-set speculative position limit (“Final Aggregation...more
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
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
The Commodity Futures Trading Commission (CFTC) has voted to seek public comment on revisions to its proposed rules requiring the aggregation of certain accounts for purposes of the CFTC's speculative position limits. If...more
The Commodity Futures Trading Commission has modified its position aggregation proposal, which initially was proposed on November 15, 2013. Under the 2013 proposal, an entity owning 50 percent or more of another entity would...more
On September 22, 2015, the Commodity Futures Trading Commission (“CFTC”) issued for public comment a supplement (the “Supplemental Aggregation Proposal”) to its proposed aggregation rules for position limits for related...more
On September 22, 2015, the Commodity Futures Trading Commission (CFTC) proposed certain changes in a supplemental notice of proposed rulemaking (the “Supplemental Notice”) to the position limit aggregation rules and...more
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
Market participants are encouraged to submit further comments to the Commission. The Commodity Futures Trading Commission (CFTC) on May 27, 2014 announced that it will hold a public roundtable at the CFTC on Thursday,...more
The US Commodity Futures Trading Commission (CFTC), on November 5, 2013, re- proposed a rulemaking (the Re-Proposed Rule) that would establish specific limits on speculative positions in 28 physical commodity futures and...more
The CFTC voted on Tuesday to propose a new position limits rule that would establish limits on speculative positions in physical commodity futures contracts. The CFTC’s previous position limits rule was vacated last year by...more
At a public meeting on November 5, the Commodity Futures Trading Commission (CFTC) voted to propose amendments to its rules requiring the aggregation of certain accounts for purposes of complying with CFTC speculative...more
Yesterday, the CFTC voted to approve a new position limits rule that resembles the agency’s previous short-lived rule (vacated and now abandoned after court challenge), albeit with certain significant changes. ...more
In this issue: - CFTC Grants Relief to CTAs and IAs from Swap Block Trade Aggregation Prohibition - Sixth Circuit Affirms Decision to Enforce Arbitration Provision in Retiree Benefit Dispute - Third...more