CFTC Grants Time-Limited Relief on Certain Position Aggregation Requirements

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.