Key takeaways

• The CFTC has adopted final rules amending the aggregation provisions of the position limits rules under Part 150. The Final Aggregation Rules maintain the general aggregation requirement in current Regulation 150.4, and add an additional aggregation requirement for a person who holds or controls positions in more than one account that employ substantially identical trading strategies.
• The Final Aggregation Rules also provide a number of exemptions from the aggregation requirements.
• While the Final Aggregation Rules will initially apply only to those futures and option contracts on nine agricultural commodities that are currently subject to the position limits regime in Part 150, if the CFTC's recently proposed position limits rules are finalized, the Final Aggregation Rules will also apply to the position limits regime for those 25 physical commodity futures and option contracts and swaps that are economically equivalent to such contracts.
• The Final Aggregation Rules will be effective 60 days after publication in the Federal Register.