Requests for Comment

CFTC Reopens Period for Commenting on Position Limit Proposals

On June 27th, the Commodity Futures Trading Commission (“CFTC”) reopened the comment period for its proposed rulemaking that would establish speculative position limits for 28 exempt and agricultural commodity futures and options contracts and the physical commodity swaps that are economically equivalent to such contracts; and its proposed rulemaking to amend existing regulations setting out the Commission’s policy for aggregation under its position limits regime. Comments on either proposal should be submitted on or before August 4, 2014. CFTC Press Release.

Regulatory Relief

FCM Relief from Providing Depository Acknowledgements

On July 11th, the CFTC’s Division of Swap Dealer and Intermediary Oversight (“DSIO”) announced it is providing additional time for futures commission merchants (“FCMs”) to comply with CFTC regulations requiring FCMs to obtain acknowledgement letters from certain depositories. DSIO will provide no-action relief until October 17, 2014. CFTC Letter No. 14-91CFTC Press Release.

Reporting Valuation Data

On July 1st, the CFTC’s Division of Market Oversight extended to June 30, 2015, the time-limited relief previously provided by CFTC Letter No. 13-34, which relieves swap dealers and major swap participants from the obligation to report valuation data for cleared swaps. CFTC Letter No. 14-90.

Masking of Identification Information

On June 27th, the CFTC’s Division of Market Oversight extended to January 16, 2015, the time-limited relief provided in CFTC Letter No. 13-41, which allows counterparties to mask legal entity identifiers, other enumerated identifiers and other identifying terms, and permits reporting entities to mask identifying information in certain enumerated jurisdictions. CFTC Letter No. 14-89.