Under the Dodd–Frank Wall Street Reform and Consumer Protection Act (commonly referred to as “Dodd-Frank”), Congress required the Commodities Futures Trading Commission (“CFTC”) to impose limits in speculative positions in physical commodity futures and options contracts and economically equivalent swaps. On November 5, 2013, the CFTC in a 3-1 vote approved a new rule (the “Rule”) that establishes position limits in 28 physical commodity futures …
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