Abstract
On 14th August, 2017, the Division of Market Oversight (DMO) at the Commodity Futures Trading Commission (the CFTC or Commission) issued time-limited no-action relief in the form of No-Action Letter (NAL) 17-37 (10th August, 2010) to delay until at least 12th August, 2019 compliance with the newly created obligation that a notice of exemption be filed with the CFTC prior to a market participant’s reliance on certain exemptions from the aggregation obligations for the purposes of speculative position limits under CFTC Rule 150.4. This paper discusses manners in which participants in light of NAL 17-37 may comply with CFTC Rule 150.4 and clarifies the distinction between the exemption for owned entities (Owned Entity Exemption) and the one for independent account controllers (IAC Exemption).
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