Commodity Futures Trading Commissioner Dawn Stump warned that she does not expect “everybody will be happy” with a revised positions limit proposal currently being considered by staff. However, she claimed there are three principles that should guide the proposal: (1) factors used to evaluate appropriate limits should be current; (2) exchanges must have an “integral role” in administering the position limits process; and (3) “one size will not fit all” – e.g., considerations in applying position limits to the hedging needs of one market should not necessarily apply to another, unrelated market. Likewise, she said, a good “common sense” outcome to the CFTC’s proposed swap execution rule amendments would be to codify existing no-action and guidance letters that have been implemented since adoption of the swap execution regime, and address the “financial resources and registration and examination of SEF professionals.” Ms. Stump made her presentation before the ISDA Annual Legal Forum. (Click here for background on the CFTC’s current work on a proposed position limits rule – now expected not to be issued prior to July 15, 2019 – in the article “Outgoing CFTC Chair Promises Workable Position Limits Proposal Before Departure; Pending New CFTC Head Says Agency Must Continue to Promote Digital Innovation” in the March 17, 2019 edition of Bridging the Week. Click here for background on the CFTC’s proposed swaps execution rules in the article “Different Roads to Travel for Swap Execution Reform Proposed by CFTC Chairman and New Commissioner” in the February 3, 2019 issue of Bridging the Week.)