CFTC Extends No Action Relief on Certain Position Aggregation Requirements

The CFTC Division of Market Oversight ("DMO") has extended time-limited no-action relief from certain position aggregation requirements under CFTC Rule 150.4 ("Aggregation of positions"). The relief applies to notice filing and aggregation obligations, including those involving owned entities, insubstantially identical trading strategies and independent account controllers. (See related coverage.) 

The extended relief was requested by the Managed Funds Association ("MFA"), Futures Industry Association ("FIA") and Asset Management Group of the Securities Industry and Financial Markets Association ("SIFMA AMG") on June 16, 2025. CFTC Letter 25-21 further extends relief originally granted in CFTC Letter 17-06 and subsequently extended by letters 17-37, 19-19 and 22-09. (See related coverage.)

Previously set to expire on the earlier of August 12, 2025, or the effective date of a final rule incorporating the no-action positions, the relief has now been extended until the later of the "effective date or compliance date" of a Commission-approved rulemaking that addresses the aggregation and notice filing obligations outlined in CFTC Letter 17-37.