CFTC Staff Provides Relief From Position Limit Aggregation Rules, Including August 14, 2017 Filing Deadline

Just days before a new notice filing requirement for certain position limit aggregation exemptions was to take effect, on August 10, 2017 the staff of the U.S. Commodity Futures Trading Commission (the "CFTC") Division of Market Oversight granted broad no-action relief to market participants subject to aggregation rules. The relief addresses not only the notice filing requirement, but also certain aspects of the aggregation exemption rules that did not reflect market realities and were unduly burdensome on market participants. This relief expires on August 12, 2019. Notably, the relief from the filing requirement does not affect the requirement to comply with the aggregation rules themselves, and market participants must be prepared to make the filing within five days of a request. The CFTC staff states in the no-action letter that it understands that exchanges intend to apply the same notice filing requirements for exchange position limits.