I'm sure you've seen this...but here goes:
Before commencing with my commentary I would like to present to you Bart's email to me on position limits and
the elimination of the phony exemptions: (courtesy Bart Chilton)
The spot month limits go into effect in 60 days after we define swaps, which we are set to do on Nov. 1st.
The all month and aggregate limits (which will include swaps) is 12 months after the initial limits. We do not have swaps data (because that required a rule requiring reporting) so can't set those level yet, but the rule requiring that they will be set (and when and how) is now in place.
On exemptions, we will grant if it is proven that there is a legitimate business risk for each day of trading (a monthly report is mandated). The historical trading is one piece of what we may look at. However, that is not a loophole that automatically grants an exemption. If that were the case, we'd simply be allowing folks to do what they have done. That is clearly not what we have allowed.
Bart Chilton.
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The position limits is to commence on Jan 1.2012 with the spot month assuming the definition of swaps arrives on Nov 1.2011. The aggregate months will commence on Jan 1.2013.
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