Andrew Cross on Futures Commission Merchants (FCMs)

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

3/22/2024 / CFTC , Commodities , Futures Commission Merchants (FCMs) , Proposed Regulation

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

3/20/2024 / CFTC , Commodities , Disclosure Requirements , Futures Commission Merchants (FCMs)

Part 10: Capital, Risk Management, and Segregation Calculations by FCMs

This post is the next installment of 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

3/19/2024 / CFTC , Futures Commission Merchants (FCMs) , Proposed Rules , Risk Management

Part 9: The One Business Day Margin Call Requirement—Miscellaneous Considerations

This post is the next in 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

3/19/2024 / CFTC , Comment Period , Futures Commission Merchants (FCMs) , Public Comment

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

3/15/2024 / CFTC , Commodities , Futures Commission Merchants (FCMs) , Proposed Rules , Separate Accounts

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

3/15/2024 / CFTC , Commodities , Derivatives , Derivatives Clearing Organizations , Futures Commission Merchants (FCMs)

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

3/14/2024 / CFTC , Commodities , Commodity Exchange Act (CEA) , Futures Commission Merchants (FCMs)

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

3/13/2024 / CFTC , Commodities , Derivatives , Futures Commission Merchants (FCMs)

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

3/12/2024 / CFTC , Derivatives Clearing Organizations , Futures Commission Merchants (FCMs) , Proposed Rules

Part 2: Separate Accounts in the Investment Management Context

This is the third of a multi-part series (Introduction; Part 1) on a February 20 proposal by the U.S. Commodity Futures Trading Commission (“CFTC”) to implement CFTC Regulation §1.44 (the “Proposed Rule”) and related...more

3/8/2024 / CFTC , Futures Commission Merchants (FCMs) , Investment Management , Investors , Proposed Rules

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

3/6/2024 / CFTC , Commodities , Commodity Exchange Act (CEA) , Futures Commission Merchants (FCMs)

Andrew Cross

Blank Rome LLP

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