CFTC no action relief on aggregation requirements

Published: 14 August 2017


The US Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) has granted no-action relief to market participants in complying with certain position aggregation requirements under CFTC rule 150.4.

This relief is being provided until 12 August 2019, replacing previous relief that was set to expire on 14 August 2017.  During the period of the time-limited no-action relief, DMO will not recommend that the CFTC take enforcement action for a market participant’s failure to comply with certain position aggregation requirements, provided the market participant complies with the terms of the relief.

In particular, the relief: revises the notice filing relief provided in CFTC Staff Letter No. 17-06; revises the definitional conditions, for purposes of complying with the aggregation requirements, for eligible entities, independent account controllers and commodity trading advisors; and limits the aggregation requirements for the “substantially identical trading strategies” rule to circumstances where the positions in more than one account or pool are held in order to wilfully attempt to circumvent applicable position limits.

Please contact Adam Jacobs-Dean ( with any comments on this.