MFA Blog

MFA and Industry Group Comment on CFTC’s Reproposed Position Limits Letter

Posted on February 28, 2017

MFA, SIFMA AMG and AIMA jointly filed a comment letter with the CFTC on the Commission’s reproposed position limits regulation. In the letter, the Associations continue to raise serious concerns with the Commission’s proposed position limits framework and reiterate the need for any new regulatory policies to be designed based on sound market and economic principles.

In the letter, the Associations specifically urge the CFTC to identify a clear standard of “excessive speculation” and incorporate that standard in its required necessity findings. The letter asks that before imposing position limits, the CFTC support why such limits are appropriate using substantive, data-driven evidence. The letter also details the need for the CFTC to revise the final aggregation rule to reduce undue compliance burdens and operational challenges.

If the Commission determines to move forward with position limits, MFA, SIFMA AMG and AIMA requested that the Commission narrowly tailor the framework to achieve a specific market outcome, in a way that is designed to be minimally disruptive, practical and not overly complicated to administer by market participants.

Click here to learn more and read MFA’s full letter.