Participants discussed Commission proposal on Position Limits.

See attached agenda for discussion topics.

Topics of discussion: timing of guidance and relief, phase-in of compliance, rolling 12-month period for MSP calculation

During the FIA's Boca 2013 Meeting, Chairman Gensler met with some of their members.  Topics of discussion included: implementation of swaps reforms, CFTC agenda for the next 6 months, customer protection (residual interest), cross-border application of swaps reform, and implementation of Regulation 1.74.

Participants discussed issues relating to SEFs and forex trading, formal agenda attached.

Discussion concerning cross-border issues.

Participants discussed the proposed margin rule for uncleared swaps. The particular issues were: cash-only variation margin; segregation of variation margin; custodian choice for excess margin; aggregation rules (definition of affiliate); implementation timeline; international harmonization and substituted compliance; and definition of eligible master netting agreement.

CME Group and counsel discussed:  deliverable supply estimation for energy and metals is different than for agricultural products, e.g., pages 4-5 of Jan. 22, 2015, CME comment letter no 60307; and the CME Group's request for parity of limit levels between cash settled and physical delivery contracts, e.g., August 4, 2014, CME comment letter no 59971.

Participants discussed comments raised, e.g., in ICE Futures U.S. comment letter no. 60310, Jan. 22, 2015:  unfixed price commitments should be basis of bona fide hedges (page 4); anticipatory hedge in softs should be recognized beyond 12 months (pages 6-7); spread exemption restrictions would restrict cash and carry exemptions by exchange (page 8); Sugar No. 11 unique delivery provisions for agricultural contract (pages 6); and aggregation should be based on control (pages 9-10).