Attorneys from Sullivan & Cromwell LLP will provide an overview and summary of the CFTC’s recently released re-proposal of its position limits rules for futures and economically equivalent swaps. Key topics to address will include the structure of the proposed limits framework (which would impose limits in the spot month and during non-spot months) and a review of the proposed exemptions from the limits for bona fide hedging positions (including the proposed process for exchange review and granting of exemptions). As time allows, the presentation will also briefly review and summarize the CFTC’s recently released final rule with respect to aggregation and exemptions from aggregation.
Ken Raisler, Partner, Sullivan & Cromwell
David Gilberg, Partner, Sullivan & Cromwell
Ryne Miller, Associate, Sullivan & Cromwell
John Miller, Associate, Sullivan & Cromwell