The International Swaps and Derivatives Association, Inc. (“ISDA”) and the Securities Industry and Financial Markets Association (“SIFMA”) appreciate the opportunity to provide the Commodity Futures Trading Commission (“Commission”) with comments and recommendations regarding the Commission’s Notice of Proposed Rulemaking on Aggregation, Position Limits for Futures and Swaps (the “Proposed Aggregation Rule” or “Aggregation Notice”).
Click here for the full ISDA/SIFMA response to the CFTC.