CMC Awaits CFTC Decision on Position Limits

After months of deliberation, the CFTC will vote on a final rulemaking tomorrow morning at 9:30 am ET.  CMC will be watching for resolution on these issues:

  • Bona Fide Hedge Definition
    • Will the Commission recognize anticipatory merchandizing transactions based on throughput and not fixed-capacity?
    • Will the Commission retain the current 30-day reporting regime or will it move to a daily reporting requirement?
  • Position Limits
    • How will the Commission handle the CME proposal for ag markets?
    • What will the effective date be?
    • Will long-term contracts be included in deliverable supply?
  • Class Limits
    • Will the CFTC allow netting of futures and swap positions?
  • Conditional Limits
    • Will the Commission address conditional limits in the final rulemaking or will it treat this issue differently?
    • Will ag markets and energy markets receive disparate treatment?
  • Aggregation
    • Beyond the independent controller exemption, are any additional exemptions made for subsidiaries of non-financial firms?
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