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FIA Files Supplemental Comment on Position Limits (July 31, 2014)

FIA submitted a comment letter to the Commodity Futures Trading Commission on July 31 in response to a request for additional comment on the agency’s proposed position limits rule and its proposed position aggregation rule. FIA focused its comments on the aggregation proposal and suggested nine changes that would address concerns raised by FIA members and other market participants. The letter also included proposed rule text provisions that reflect the suggested changes.

CFTC Further Extends the Reopened Comment Period for its Rulemaking Proposals on Position Limits for Physical Commodity Derivatives and Aggregation (June 27, 2014)
The CFTC further extended the public comment period for the proposed position limits rule, as well as the related proposal regarding aggregation of positions across commonly owned affiliates.  The extension will run for 30 additional days after it is published in the Federal Register. 

FIA Special Report: CFTC Discusses Cross-Border Issues (May 23, 2014)
The Commodity Futures Trading Commission's Global Markets Advisory Committee held a meeting on May 21 to discuss cross-border regulatory issues. The advisory committee, which is comprised of industry representatives and other experts, has no rule-making authority, but both of the current CFTC commissioners attended the entire meeting and the discussion provided some insights into the agency's position on several key cross-border issues.

FIA Opposes LCH.Clearnet Proposal for Covering Losses from Treasury Management (April 11, 2014)

On April 11, FIA submitted a letter to LCH.Clearnet Limited expressing opposition to a proposed mechanism for covering losses incurred by LCH.Clearnet in its treasury management activities. Under this proposal, LCH.Clearnet would set aside 15 million euros of its own capital to cover such losses, but if this amount is insufficient, LCH.Clearnet would allocate the remainder to its members. In its letter, FIA commented that the proposed rules, if applied to customer property, would violate certain regulations of the Commodity Futures Trading Commission. FIA also said that the proposed rules would create "undue and potentially unlimited and unquantifiable risk" for members of the clearinghouse.

U.S. and European Trade Associations Issue Joint Statement on Transatlantic Trade and Investment Partnership (Mar. 25, 2014)

FIA joined with 14 other U.S. and European trade associations in urging policymakers in the U.S. and Europe to include financial services in the Transatlantic Trade and Investment Partnership. The joint statement was issued on March 25 in advance of the EU-U.S. Summit in Brussels on March 26 attended by U.S. President Barack Obama, European Council President Herman Van Rompuy and European Commission President José Manuel Barroso.

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