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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 4: CFTC Regulation 1.44—Key Definitions

The previous post in this series discussed how different market participants hold different views of the relationship between an investment manager and its clients, particularly in the separate account context. That post...more

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