Insider Trading and Position Limits

Abstract

Federal law has long prohibited insider trading in securities such as stocks and bonds. Yet many other financial assets—particularly derivatives and commodities—have historically fallen outside those rules.

This Article asks why insider trading is penalized for some assets but not others. It argues that the goals of insider trading law are often pursued through alternative mechanisms. Markets lacking insider trading prohibitions are not unregulated; rather, they are governed by substitute regimes that achieve similar ends through different means.

By examining the relationship between securities insider trading law and derivatives position limits, this Article clarifies the function of insider trading regulation and illuminates its boundaries. It shows that position-limit rules, though rarely analyzed in this way, can serve as functional substitutes for insider trading restrictions, offering a broader perspective on how law manages informed trading across markets.

About the Author

Professor of Law and Vice Dean for Curriculum and Academic Affairs, UCLA School of Law. Faculty Director, Lowell Milken Institute for Business Law and Policy. I am grateful for the keen insight of Ilya Beylin, Merritt Fox, Jeffrey Gordon, Zohar Goshen, Henry Hu, Paolo Saguato, Richard Squire, and the participants at the Fordham Law & Columbia Law School conference Celebrating the Enduring Influence of Zohar Goshen and Gideon Parchomovksy’s Seminal Article, The Essential Role of Securities Regulation. I am likewise grateful to Drew Downing, Rohan Gandhi, and Eden Yeh for excellent research assistance.

By LRIRE