July 24, 2018

Concurring Statement of CFTC Commissioner Rostin Behnam Regarding the Position Limits and Position Accountability for Security Futures Products Proposed Rule

I respectfully concur with the Commodity Futures Trading Commission’s approval of its proposed rule regarding Position Limits and Position Accountability for Security Futures Products (Proposal).  I commend staff on their hard work in producing this Proposal, and for their thoughtful responses to my questions.  I look forward to hearing from market participants and other stakeholders regarding the amendments to the existing position limits rules for security futures products.  In particular, I will be interested in comments regarding the appropriateness of increasing the default level of equity security futures products position limits from 13,500 contracts to 25,000 contracts.  While today’s Proposal only would amend the Commission’s Part 41 rules regarding security futures products, I nonetheless encourage market participants and interested stakeholders to consider how the Proposal might impact or interplay with the Commission’s position limits rules in Part 150 and any future amendments to them.