The Dodd-Frank Wall Street Reform and Consumer Protection Act is a federal statute in the United States that was signed into law on July 21, 2010. The Act sets sweeping changes for the financial services industry, and more specifically for the listed and over-the-counter derivatives (OTC) markets. Financial rules are being crafted by the regulators as the U.S. Commodity Futures Trading Commission (CFTC) to establish oversight of OTC derivatives; create new roles for intermediaries and traders; determines what types of swaps will move to clearinghouses and who will be granted exemptions; and sets capital and margin requirements for swaps dealers and major participants.

The new law also gives the CFTC authority to establish position limits on both the futures and OTC markets and sets a tight deadline for establishing these limits - 270 days for agricultural commodities and 180 days for other types. These position limits will apply to an entity's positions on designated contract markets, on Swap Execution Facilities, in OTC significant price discovery contracts and, in some cases, on foreign boards of trade. The CFTC must rework its controversial energy position limits plan to comply with the new law.

The new CFTC aggregate caps are in addition to any levels and limits set by the exchanges, and apply to an entity's aggregate positions across markets. These increased position limits are expected to place an even greater oversight responsibility on compliance, trading and operations staff. Firms also must stringently monitor positions intra-day to avoid breaches; as it remains a violation of the Commodity Exchange Act and CFTC regulations if the limit is breached at any time during the day, even if the position is subsequently reduced to below the limit by the close of the market.

To help you manage your compliance responsibility, the IFM offers a unique industry utility - the Position Limits Databank (or PLD) - a static data storehouse that can be integrated into your internal control system to monitor positions and set trade parameters. Our service provides accountability levels reporting levels, position limits, contract aggregation, diminishing contract indicators, mini contract multipliers and more on 75 global futures and options on futures exchanges.

The PLD was developed at the request of the Futures Industry Association Law & Compliance Division to help market participants meet their regulatory obligations and was underwritten by global financial firms. It used daily by banks, futures commission merchants, as well as hedge and investment firms to monitor reporting and accountability levels, discover near-excess positions, file for exemptions and guard against exchange warnings, suspensions, fines or regulatory action.

IFM Provides 79,200 Data Fields on 75 Exchanges and
Helps You Stay Compliant, Save Money and Avoid Fines.

The PLD is provided via a low-cost annual enterprise-wide data subscription. - Our variety of data formats also makes it easy to use and to integrate into your control system.

Position Limits Databank Features:

• Data are provided in various user formats including HTML and Excel via the Web, or through ASCII and XML downloads via FTP facilities. Download options include the entire database file or the bulletin file of changes.
• Data are monitored daily by the IFM and continuously updated to help mitigate risk caused by inaccuracy or latency.
• Search and Compare Tool
• Archives
• Users also receive critical alert emails to stay informed of changes. These alert emails are issued approximately 3 times per week.
• IFM Data Center Help Desk available via telephone or email to answer questions or investigate concerns.

The New Wall Street Reform Act Increases Your Compliance
Responsibility to Monitor Position Limits - Intra-day and Everyday.

IFM Makes It Easier and Cheaper.

As a nonprofit foundation, the IFM can help you significantly reduce costs and staff hours spent in sourcing, manually aggregating and compiling data on your own. For a list of futures and options exchanges and platforms covered see brochure.

For more details or to schedule a 15-minute online live demonstration, please call 202.223.1528 or email info@theIFM.org.