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Compliance with the owned entity and independent account controller exemptions under CFTC Rule 150.4

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  • Jackson, Carolyn

Abstract

On 14th August, 2017, the Division of Market Oversight (DMO) at the Commodity Futures Trading Commission (the CFTC or Commission) issued time-limited no-action relief in the form of No-Action Letter (NAL) 17-37 (10th August, 2010) to delay until at least 12th August, 2019 compliance with the newly created obligation that a notice of exemption be filed with the CFTC prior to a market participant’s reliance on certain exemptions from the aggregation obligations for the purposes of speculative position limits under CFTC Rule 150.4. This paper discusses manners in which participants in light of NAL 17-37 may comply with CFTC Rule 150.4 and clarifies the distinction between the exemption for owned entities (Owned Entity Exemption) and the one for independent account controllers (IAC Exemption).

Suggested Citation

  • Jackson, Carolyn, 2018. "Compliance with the owned entity and independent account controller exemptions under CFTC Rule 150.4," Journal of Financial Compliance, Henry Stewart Publications, vol. 1(4), pages 364-372, May.
    • Handle: RePEc:aza:jfc000:y:2018:v:1:i:4:p:364-372
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    More about this item

    Keywords

    CFTC Rule 150.4; position limits; aggregation; exemption; independent account controller; owned entity;
    All these keywords.

    JEL classification:

    • G2 - Financial Economics - - Financial Institutions and Services
    • E5 - Macroeconomics and Monetary Economics - - Monetary Policy, Central Banking, and the Supply of Money and Credit
    • K2 - Law and Economics - - Regulation and Business Law

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