News Article By all evidence most CTAs will not be affected by position limits because they don't take positions of such magnitude. The CFTC estimates that relatively few traders have positions large enough to hit the proposed ceilings. In summary, new CFTC rules will affect brokers, dealers and very large futures traders, but not the average CTA-at least not directly. Publication Opalesque Date January 7, 2011 Cross References (links may require a Cabinet subscription) Dodd-Frank Act, Title VII, Sec. 737

Commentary Discussing the history of governmental regulation of position levels in the futures markets, Professor Craig Pirrong warns against the intervention that forced large traders to liquidate their positions "in an overtly politicized environment." Citing past intervention by the Grain Futures Administration-the great-grandfather of the CFTC-Pirrong observes that there is a history of intervention in the market "for political purposes, rather than on the basis of a well-reasoned and empirically supported concern that the market had in fact been distorted by the actions of a particular

News Article The largest speculators in U.S. commodity markets have little to fear from a new plan by their regulator for heightened surveillance -- a precursor to position limits that won't likely force anyone to exit trades. The new plan, involving "position points" rather than strict limits, is an attempt to appease CFTC Commissioner Bart Chilton, who says the agency should act faster to make sure speculators cannot help drive up prices at a time when food and copper have hit records and oil nears $100 a barrel. It is an interim measure until the CFTC has the data needed to put in place

News Article Proposals to force pension funds to clear OTC derivatives centrally could increase risk levels for pension funds due to increased costs from complying with margin requirements, forcing such funds to engage in riskier investment strategies to make up the difference. The article quotes Tom Kirby, director, regulatory and risk management at Ernst Young as saying: "In a worst case scenario, a whole range of costs will increase, and the increases will be worse if there is initial and variation margin segregation on top. These will all be passed on to the buy-side as fees." Publication

News Article The CFTC does not plan to toughen their proposal to limit banks' voting power in derivatives clearing and trading venues, despite concerns by the Justice Department the rule may not combat anti-competitive practices, according to people familiar with the matter. A draft of a final rule, which is slated for a vote by the CFTC on Thursday, would place percentage caps on the voting shares that clearing and trading member firms can control, and would also shake up the board structure at clearing and trading venues by requiring more representation by public directors. But the plan's