MFA and SIFMA AMG Submit No-Action Request Letter to CFTC

On July 17, MFA and SIFMA AMG submitted a request to the CFTC Division of Market Oversight for No-Action relief from certain position limits aggregation requirements.  The Association’s request seeks:

  • Relief from position limits aggregation notice requirements unless/until the CFTC or an exchange provides notification of a potential breach of a federal position limits on an aggregated basis, after which the participant will be given 5 days to file a disaggregation notice;
  • Expansion of the definition of independent account controller and eligible entity to include an exempt CTA;
  • Expansion of the definition of eligible entity to include any entity that has authorized an independent account controller to act in a fiduciary capacity; and
  • Limiting the Substantially Identical Trading Strategies aggregation requirement to willful circumvention.
  • The Associations also join in FIA’s request to streamline the eligible entity requirements.