The CFTC recently settled with market participants that violated the CFTC’s ‘position limits’ rules. The CFTC orders filing and settling these charges include aggregating position limits across exchanges. The CFTC also recently finalized guidance on listing derivatives on voluntary carbon credits (VCC).

Why this matters:

• Any company with traders who trade on CFTC-licensed exchanges must understand the position limits requirements as they are applied across exchanges.
• The guidance on VCC derivatives applies directly to CFTC-registered exchanges but will likely also affect the standards used by market participants in spot VCC markets.
• Companies should consider whether their policies and procedures reflect these recent CFTC developments.