CFTC is expected to announce a new position limit regime for energy derivatives markets by December 21. It is unclear whether new rules for energy products will resemble hard limits or softer accountability levels, which involve market participants making increased disclosures about the nature of big positions. Limits could place constraints on a fund or dealer’s total exposure or “look through” to its individual customers’ accounts. Any new position limit regime is likely to encourage energy investors and hedgers to look outside the US.