Compliance with the owned entity and independent account controller exemptions under CFTC Rule 150.4

Carolyn Jackson

Journal of Financial Compliance, 2018, vol. 1, issue 4, 364-372

Abstract: On 14th August, 2017, the Division of Market Oversight (DMO) at the Commodity Futures Trading Commission (the CFTC or Commission) issued time-limited no-action relief in the form of No-Action Letter (NAL) 17-37 (10th August, 2010) to delay until at least 12th August, 2019 compliance with the newly created obligation that a notice of exemption be filed with the CFTC prior to a market participant’s reliance on certain exemptions from the aggregation obligations for the purposes of speculative position limits under CFTC Rule 150.4. This paper discusses manners in which participants in light of NAL 17-37 may comply with CFTC Rule 150.4 and clarifies the distinction between the exemption for owned entities (Owned Entity Exemption) and the one for independent account controllers (IAC Exemption).

Keywords: CFTC Rule 150.4; position limits; aggregation; exemption; independent account controller; owned entity (search for similar items in EconPapers)
JEL-codes: E5 G2 K2 (search for similar items in EconPapers)
Date: 2018
References: Add references at CitEc
Citations:

Downloads: (external link)
https://hstalks.com/article/1519/download/ (application/pdf)
https://hstalks.com/article/1519/ (text/html)
Requires a paid subscription for full access.

Related works:
This item may be available elsewhere in EconPapers: Search for items with the same title.

Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text

Persistent link: https://EconPapers.repec.org/RePEc:aza:jfc000:y:2018:v:1:i:4:p:364-372

Access Statistics for this article

More articles in Journal of Financial Compliance from Henry Stewart Publications
Bibliographic data for series maintained by Henry Stewart Talks ().