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Staff is considering recommending that the Commission amend the position limits and position accountability rules for security futures products (SFPs) by: (1) increasing the default level of equity security SFP position limits; (2) eliminating other specific position limits and position accountability levels, instead permitting the listing exchange to set specific position limits and position accountability levels for SFPs above the default level where appropriate; and (3) requiring aggregation of positions held by the same person in cash-settled SFPs and physical delivery SFPs that are based on the same underlying security.