Publications: Papers

Analysis of Recent CFTC Position Limit Proposal (February 2014)


In this comment letter, Dr. Vervleger reviews the CFTC's recent notice of proposed rulemaking on position limits for derivatives. Specifically, he provides an analysis of the CFTC’s recent position limit proposal, including the likely costs that will result from implementing the proposed limits. The analysis demonstrates that setting position limits on non-spot-month contracts will have no positive economic benefits but could have serious economic costs.


This letter was included as Annex A to the February 10, 2014, ISDA/SIFMA position limit comment letter posted on the CFTC website. See Comment for Proposed Rule 78 FR 75680 by Chris Young.


(Note: This paper is available on request.)