What Constitutes Proof of Bona Fide Hedging Under the CFTC's New Position Limits Final Rule and Eligibility for End-User/Hedging-Affiliate Exception to Clearing

Time: Tuesday, October 12, 2021 - 9:00am to 10:00am
Level: Intermediate/Advanced
Room: Grand Ballroom E


As the compliance date of January 1, 2022, under the CFTC's new Position Limits Final Rule gets nearer, the swap dealer community, the CFTC Staff, and commercial end users of uncleared bilateral swaps are all asking what we should be requiring as proof that a swap counterparty and its swap transaction are (i) eligible for exclusion from any applicable Position Limit as a Bona Fide Hedge (BFH) and (ii) eligible to elect the End-User Exception or the Hedging-Affiliate Exception to clearing under CEA Section 2(h)(7)(A) or (D).

1 hr CLE


  • A deep dive into what is a proof of Bona Fide Hedge and the new Position Limits.