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The CFTC Division of Market Oversight ("DMO") granted time-limited relief to a master fund
investment manager, a related holding company, and the four
shareholders of the company from compliance with certain position
aggregation requirements under
CFTC Rule 150.4. The Division granted the relief even though
transaction information firewalls were not maintained (as normally
required for such an exemption), because the transaction
information is being used only for currency hedging performance
evaluation and risk management monitoring.
DMO also cited the fact that the relief is limited to
transactions in major foreign currencies.
The no-action relief will remain effective until 12:01 a.m. EST
on November 15, 2021, or until the parties are otherwise
notified.
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.
