News & Analysis as of

Aggregation Rules Compliance

Ropes & Gray LLP

Welcome Relief - CFTC Staff Extends No-Action Relief on Position Aggregation Requirements

Ropes & Gray LLP on

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

Latham & Watkins LLP

CFTC Re-Proposes Position Limits Rule and Proposes Revised Aggregation Requirements

Latham & Watkins LLP on

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

Goodwin

CFTC Issues Revised Position Limits Rule Proposal and Proposes Related Aggregation Standards

Goodwin on

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

Broker-Dealer Compliance + Regulation

SEC Won’t Object To Aggregation of Certain Client Investments in Private Funds

In a Guidance Update published this week, the SEC’s Division of Investment Management said that it would not object if related investment advisors registered jointly with the SEC and operating a single advisory business...more

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