CFTC Rule 4.13(a)(3) Pool Investors:
The $1Million Potato

The Commodity Futures Trading Commission (“CFTC”) has for many years imposed limits on the size of speculative position limits that any one person may hold in certain futures contracts and options on futures contracts. Post-Dodd-Frank, the CFTC has for not quite as many years attempted also to bring similar position limits to the over-the-counter swap markets, and appears poised to do so soon, on their fourth or fifth attempt—depending on how you count them.