March 29, 2017

CFTC Provides Time-Limited No-Action Relief for Aggregation Notice Filings for Position Limits

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On February 6, 2017, the Commodity Futures Trading Commission (CFTC) Division of Market Oversight (DMO) 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 certain aggregation exemptions from federal position limit levels. Before this relief began on February 14 2017, market participants would have been required to file notices to rely on certain aggregation exemptions under CFTC Regulation 150.4(c).

View full memo, CFTC Provides Time-Limited No-Action Relief for Aggregation Notice Filings for Position Limits

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Donna Parisi

Partner

Derivatives & Structured Products

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Geoffrey Goldman

Partner

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Azam Aziz

Partner

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New York