On Sept. 12, 2024, the Commodity Futures Trading Commission (CFTC) took another step toward limiting the availability and scope of relief provided by CFTC Regulation 4.7 (Reg. 4.7) under the Commodity Exchange Act, as amended (CEA). Although the changes adopted in the final rule (Final Rule) are less comprehensive than those the CFTC had proposed earlier in the year (Proposed Rule), they are the latest in a series paring back both the extent to which Reg. 4.7 can be invoked and the relief from certain regulatory requirements it provides.