CFTC Adopts Position Limit Proposal at Ninth Open Meeting Implementing Dodd-Frank

On January 13, 2011, the Commodity Futures Trading Commission ("CFTC") held its ninth public meeting to consider proposed rulemakings implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act. The CFTC approved for public comment proposed rules addressing:

• Position limits for physical commodity derivatives, and
• Swap trading relationship documentation for swap dealers and major swap participants.

The following is based on the discussion at the CFTC's public meeting and related material published by the CFTC. Public comments on both proposed rules are due 60 days after publication in the Federal Register. As of the preparation of this briefing, the proposed rules have not been published in the Federal Register.