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Ex Parte Meeting for Proposed Rule 83 FR 36799

  • Title:
    Call with David Downey on the SFP Position Limit NPRM

    Ex Parte No: 1290
    Date: 11/20/2018

    Meeting Date:

    Tuesday, November 20, 2018

    CFTC Staff:

    Thomas Leahy

    Greg Kuserk

    David Van Wagner 



    External Attendees:

    David Downey

    Additional Information:

    Discussed the need to continue with the SFP position limit rulemaking.  David Downey noted that traders face frictions in the futures market that don't exist in the OTC market and that traders must trade in size.  He also noted that the five-day period for position limits is arbitrary.


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