The CFTC Division of Market Oversight (the "Division") granted time-limited relief to two companies from compliance with certain position aggregation requirements under CFTC Rule 150.4.

The no-action relief is limited to the "firewall conditions for the owned entity exemption in [CFTC Rule] 150.4(b)(2)(i)(D) in connection with cash-market trading decisions," which ordinarily permits disaggregation where an owner and an owned entity do not share employees that control trading decisions. The Division provided relief even though the two entities share an employee who controls the cash market, but not the derivatives trading decisions, of the owned company.

The no-action relief will remain in effect until 12:01 a.m., Eastern Standard Time, on August 12, 2019.

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.