FIA and ISDA filed a petition seeking clarity on the definition of swaps that will be subject to the CFTC position limits rule. Beginning January 1, 2023, the CFTC limits will apply to "economically equivalent swaps,” which is to say, swaps that have identical material contractual terms to futures and options that are subject to the federal limits. The petition asks the CFTC to exercise its authority under the rule to clarify the definition of economically equivalent swaps to allow market participants to comply with the limits and implement effective position monitoring systems and processes.
