Update on CFTC Rulemaking: CFTC Issues Final Rules on Position Limits for Commodity Futures and Swaps


At its open meeting on October 18, 2011, the Commodity Futures Trading Commission ("CFTC") adopted final rules (the "Position Limit Rules") to establish speculative position limits for 28 physical commodity futures and options contracts ("Core Referenced Futures Contracts") and futures, options, swap, or swaption contracts that are economically equivalent to such Core Referenced Futures Contracts (together with the Core Referenced Futures Contracts, collectively, "Referenced Contracts"). The position limits will restrict the net long or short positions that traders may hold or control in Referenced Contracts in a particular commodity, subject to exemptions for certain pre-existing positions and positions falling within a bona fide hedging exemption.

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