Aaron D. Withrow
Washington, D.C. +1 202 261 3442
The Commodity Futures Trading Commission (“CFTC”) recently adopted a position limits regime for 28 agricultural, metals and energy commodity futures and options contracts, as well as over-the-counter derivatives that are economically equivalent to such contracts. In addition to the position limits, the new rules address designated contract market and swap execution facility setting of position limits and accountability levels, modify requirements related to aggregation of accounts for purposes of compliance with the position limits, implement new position visibility requirements and provide certain exemptions. This update examines the new position limits regime and how it may affect asset managers and their business.