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Part 12: Amendments to Other CFTC Regulations to Account for Proposed Regulation §1.44

This post is the final installment of our multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”)....more

Part 11: Information and Disclosure Requirements in the Separate Account Context

This post is the next installment of multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”)....more

Part 8: The One Business Day Margin Call Requirement under CFTC Regulation §1.44

This post is an overview of the “one business day margin call requirement” that applies to separate account customers under CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on...more

Part 7: The Ordinary Course of Business and the Separate Account Election

This post is the next installment in a multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”)....more

Part 6: The Treatment of Separate Accounts—General Conditions

This post is the next installment in a multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”)....more

Part 5: The Margin Adequacy Requirement of Proposed CFTC Regulation §1.44

This post continues our multi-part series on proposed CFTC Regulation §1.44 (the “Proposed Rule”). If adopted, the Proposed Rule will require every futures commission merchant (“FCM”) to ensure that a customer does not...more

Part 1: The Margin Adequacy Requirement under CFTC Rule 1.44 Generally

This is the second of a multi-part series on a February 20 rule proposal by the U.S. Commodity Futures Trading Commission (“CFTC”) to...more

Introduction: CFTC Proposes Regulations to Address Margin Adequacy and to Account for the Treatment of Separate Accounts by...

On February 20, 2024, the U.S. Commodity Futures Trading Commission (the “CFTC”) proposed regulations under the Commodity Exchange Act (the “CEA”) that will be of particular interest to futures commission merchants (“FCMs”)...more

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