ARTICLE
23 November 2018

CFTC Grants Time-Limited Relief On Certain Position Aggregation Requirements

CW
Cadwalader, Wickersham & Taft LLP
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
DMO also cited the fact that the relief is limited to transactions in major foreign currencies.
United States Finance and Banking
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The CFTC Division of Market Oversight ("DMO") granted time-limited relief to a master fund investment manager, a related holding company, and the four shareholders of the company from compliance with certain position aggregation requirements under CFTC Rule 150.4. The Division granted the relief even though transaction information firewalls were not maintained (as normally required for such an exemption), because the transaction information is being used only for currency hedging performance evaluation and risk management monitoring.

DMO also cited the fact that the relief is limited to transactions in major foreign currencies.

The no-action relief will remain effective until 12:01 a.m. EST on November 15, 2021, or until the parties are otherwise notified.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

ARTICLE
23 November 2018

CFTC Grants Time-Limited Relief On Certain Position Aggregation Requirements

United States Finance and Banking
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
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