CFTC Staff Interpretation Regarding Part 22

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On November 1, the CFTC Division of Clearing and Risk issued a staff interpretation letter which clarifies certain operational issues regarding the implementation of Part 22. Under Part 22, Futures Commissions Merchants and Derivatives Clearing Organizations must legally segregate each Cleared Swaps Customer’s collateral, but are permitted to operationally commingle the collateral of their Cleared Swaps Customers. CFTC Interpretation.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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