By Stephen A. Keen and Andrew P. Cross 

Our last two posts surveyed what Rule 18f-4 and its adopting release (the “Release”) tell us about excluding currency and interest-rate derivatives from the derivatives exposure of a fund seeking to comply with the Limited Derivatives User requirements of Rule 18f-4(c)(4). The Release indicates that

Compliance and trading professionals of firms that trade energy derivatives over NYMEX and COMEX should be aware of a recent development related to hedging, risk management, and arbitrage/spread position exemptions from position limits under Rule 559 (Position Limits and Exemptions).
Continue Reading Attention Energy Traders: CFTC Focuses on Verification of Position Limit Exemptions for Hedging and Risk Management Transactions