Commodity Futures Trading Commission proposes position limits for commodity derivatives *

USA - February 14 2011
The Commodity Futures Trading Commission (the "Commission" or "CFTC") is proposing to establish a framework for implementing position limits for certain physical commodity derivatives, including exchange-traded futures and options on futures contracts and swaps that are economically equivalent to such contracts, in accordance with Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act").

Co-authors: David S. Mitchell, Mark Molle.

CFTC proposes elimination of commodity pool operator registration exemptions and new reporting and compliance obligations *

USA - February 8 2011
As part of implementing new statutory provisions enacted by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"), the Commodity Futures Trading Commission (the "CFTC") is proposing rules that would (i) rescind exemptions from commodity pool operator ("CPO") registration under CFTC Rules 4.13(a)(3) and 4.13(a)(4).

Co-authors: David S. Mitchell, David W. Selden, Mark Molle.