CMC Meets with Senior Staff at CFTC

CMC recently met with senior staff at the CFTC to discuss various issues under the position limits rulemaking, including aggregation and reporting. CFTC staff advised us that they were working on the petitions that had been filed by the Energy Working Group on these topics, and acknowledged CMC’s letters of support for those petitions.

On the subject of monthly reporting of daily positions, the CFTC believes that the new form that they have asked market participants to use as a template (Form 404) will be a little more burdensome to comply with than the current Form 204, but not prohibitively so. The CFTC is instituting an online process to file Form 404. Clearly, the CFTC’s opinion is that significant benefits (in excess of the costs imposed on industry) will accrue to the Commission from a surveillance perspective by seeing the daily positions data on a monthly basis.

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