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ARTICLE · 19 AUGUST 2022

CFTC Staff Extends Relief With Respect To Certain Position Limit Aggregation Requirements

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On August 10, 2022, staff of the U.S. Commodity Futures Trading Commission (CFTC) issued No-Action Letter 22-09,1 which provides relief with respect to the position limit disaggregation...

United StatesFinance and Banking
Jan-Paul Bruynes
Jan-Paul Bruynes
Brian T. Daly
Brian T. Daly
Jason M. Daniel
Jason M. Daniel
W. Graham McCall
W. Graham McCall
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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 controller" disaggregation exemption.

On August 10, 2022, staff of the U.S. Commodity Futures Trading Commission (CFTC) issued No-Action Letter 22-09,1 which provides relief with respect to the position limit disaggregation notice filing requirements under Rule 150.4(c),2 as well as certain other interpretive relief. The letter marks the second extension of all relief originally provided in CFTC No-Action Letter 17-37 until the earlier of August 12, 2025, and the effective date of a rulemaking codifying the no-action relief. Please refer to Akin Gump's prior client alert for an overview of the no-action relief.3

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