Julian Hammer

Morrison & Foerster discusses Final Interpretation Regarding Forward Contracts with Embedded Volumetric Optionality Issued by CFTC and SEC

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On May 12, 2015, the Commodity Futures Trading Commission (“CFTC”) and Securities and Exchange Commission (“SEC”) jointly issued the CFTC’s final interpretation clarifying its interpretation concerning forward contracts with embedded volumetric optionality (“Final Interpretation”). The Final Interpretation appears to signal …

Morrison & Foerster discusses CFTC Speculative Position Limits Proposal

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On November 5, 2013, the Commodity Futures Trading Commission (“CFTC” or “Commission”) proposed new speculative position limits. The proposal (“New Proposal”) would establish spot-month and non-spot-month limits for 28 core physical commodity contracts and their “economically equivalent” futures, options, and

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