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On February 6, 2017, the CFTC's Division of Market Oversight issued a time-limited no-action letter stating that, from February 14, 2017 to August 14, 2017, it will not recommend an enforcement action for failure to file a notice when relying on certain aggregation exemptions from federal position limit levels.
On February 6, 2017, the CFTC's Division of Market Oversight
issued a time-limited no-action letter stating that, from February
14, 2017 to August 14, 2017, it will not recommend an enforcement
action for failure to file a notice when relying on certain
aggregation exemptions from federal position limit levels. Absent
this relief, on February 14, 2017, market participants would have
been required to file notices to rely on certain aggregation
exemptions under CFTC regulation 150.4(c).
DMO also announced the availability of a portal that provides
the form and manner for filing aggregation exemption notices. This
new portal is available on the Forms & Submissions page of www.cftc.gov.
Although the no-action letter provides temporary relief from the
aggregation notice filing compliance date of February 14, 2017, DMO
is providing the portal for participants who choose, of their own
accord during the relief period, to file a notice with the CFTC of
their intent to take advantage of certain aggregation exemptions
under CFTC regulation 150.4(c).
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.