New CFTC Rules for Derivatives Positions: Knowing Your Limits


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On October 15, 2020, the CFTC concluded a decade-long effort to modernize and expand its existing speculative position limits regime for certain U.S. exchange-listed physical commodity futures contracts. Akin Gump partner JP Bruynes and AIMA senior advisor Suzan Rose will discuss how the final rule will, among other things expand the scope of physical commodity derivative contracts to which federal speculative limits apply; re-set existing limits based on updated deliverable supply estimates; and provide exchanges with greater discretion to administer bona fide hedging exemptions.


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