On October 27th, the CFTC published the adopting release and text of new final rules governing position limits for futures and swaps. The new rules set limits on speculative positions in 28 core physical commodity contracts and their "economically equivalent" futures, options, and swaps (collectively "Referenced Contracts"). The establishment of speculative limits on Referenced Contracts will occur in two phases. Spot-month limits will be effective sixty days after the term "swap" is defined under the Dodd-Frank Act. For the nine "legacy" agricultural Referenced Contracts that currently are subject to CFTC-administered limits, the new non-spot-month limits will go into effect sixty days after the term "swap" is further defined under the Dodd-Frank Act. For all other Referenced Contracts, the limits will be made effective by order after the CFTC has received one year of open interest data on physical commodity cleared and uncleared swaps under the swaps large trader reporting rule.