SIFMA’s Asset Management Group (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (Commission) regarding the Supplemental Notice of Proposed Rulemaking on Aggregation of Positions. SIFMA AMG has a significant interest in the Commission’s aggregation requirements for speculative position limits due to the impact these requirements can have on both asset managers’ and their clients’ ability to operationalize compliance with position limits and the
related burdens that can diminish investors’ returns.

See also:
CFTC Rule – Aggregation of Positions