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Adobe PDFCFTC Staff Clarifies Scope of Swap Definition: CFTC’s Office of General Counsel Responds to Questions Regarding Certain Physical Commercial Agreements
David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article
November 16, 2012, previously published on November 15, 2012
On November 14, 2012, the Officer of the General Counsel (the “OGC”) of the Commodity Futures Trading Commission (the “CFTC”) issued a response to frequently asked questions (the “FAQ”) in which it clarified the scope of the definition of the term...

 

Adobe PDFCFTC Proposes Aggregation Exemptions: Proposal Would Expand Exemptions from Aggregation under the New Position Limit Rules, Including For Non-Majority Investments
Whitney A. Chatterjee, David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article
May 24, 2012, previously published on May 21, 2012
On October 18, 2011, the Commodity Futures Trading Commission (the “CFTC”) adopted final position limit rules (the “Position Limit Rules”). The Position Limit Rules establish Part 151 of the CFTC’s Regulations, which will impose spot- and non-spot-month limits...

 


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