On March 24, 2009, the Federal Register published the Commodity Futures Trading Commission’s (CFTC’s) advance notice of proposed rulemaking and request for public comment in connection with a commission recommendation to review whether to eliminate the bona fide hedge exemption for swap dealers and to replace it with a limited risk management exemption. The recommendation was part of the September 2008 "Staff Report on Commodity Swap Dealers and Index Traders with Commission Recommendations" prepared as a result of commission special calls for information from swap dealers and index traders issued in June and July 2008. The limited risk management exemption would be conditioned by the requirement that swap dealers report to the CFTC and self-regulatory organizations when "certain noncommercial swap clients reach a certain position level" or certify that none of the clients exceed certain position limits in exchange-regulated commodities. The report stated that the exemption "would essentially look through the swap dealer to its counterparty traders." The notice requests comments on three topics: general advisability of eliminating the existing bona fide hedge exemption for swap dealers in favor of a limited risk management exemption, scope of a potential new limited risk management exemption for swap dealers and terms of a potential new limited risk management exemption for swap dealers. Comments are due on or before May 26, 2009.