Key takeaways:

• The CFTC issued final rules on position limits with respect to 28 physical commodities (including crude oil, natural gas, gold and copper). The final rules will restrict the amount of futures, swaps and other similar contracts on such commodities any person can hold or trade.
• The initial spot-month limits will apply 60 days after the CFTC issues final rules on the definition of 'swap.' The initial non-spot-month and all-months-combined limits will be determined by the CFTC after it collects information on all open interest on those commodities.
• Position limits will not apply to bona fide hedging transactions, which are rather narrowly defined.
• In certain cases, positions in the relevant futures and swaps held or controlled by a single person or related persons in multiple accounts will need to be aggregated for the purpose of applying position limits.