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The CFTC's Division of Market Oversight issued interpretive guidance regarding CFTC Regulation 150.4(b)(1), which is an exemption from position aggregation requirements for certain commodity pool investors.
The CFTC's Division of Market Oversight issued interpretive
guidance regarding CFTC Regulation 150.4(b)(1), which is an
exemption from position aggregation requirements for certain
commodity pool investors. In response to a request for
interpretation, the staff letter confirms that, for purposes of
applying the position limits set forth in CFTC Regulation 150.2,
when an institutional investor qualifies for the Regulation
150.4(b)(1) exemption from position aggregation with respect to
their investment in a fund, the institutional investor is not
required to look through its investment in a fund to aggregate
commodity interest positions of an underlying portfolio company in
which the institutional investor may hold a 10% or greater indirect
interest (via its investment in the fund).
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