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Clients rely on our Finance Group to help them navigate the business and legal complexities of novel and multi-dimensional debt financing transactions. Our versatile finance practitioners work closely with our mergers and acquisitions, securities, tax, real estate and bankruptcy lawyers to provide seamless advice and innovative solutions that address our clients' debt financing needs related to all types of transactions and capital structures.
CFTC Adopts Position Limits Rule, Proposes to Extend Temporary Exemptive Relief From the Applicability of Certain Swap Provisions of the Dodd-Frank Act
November 10, 2011
On October 18, 2011, the Commodity Futures Trading Commission adopted a final rule regarding position limits for certain physical commodity derivatives (the "Final Rule"). The Final Rule establishes position limits for 28 commodity futures contracts as well as futures, options and swaps that are economically equivalent to those contracts. These position limits will apply across different trading venues to each contract based on the same underlying commodity. At the same time, the CFTC also proposed to extend earlier temporary exemptive relief granted to swap market participants from various requirements under the Commodity Exchange Act, as amended by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 for an additional six months to July 16, 2012 to provide legal certainty and avoid undue disruption of the swap markets during transition to the new regulatory framework.