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Interpretative Letters

Date
Interpretative Letters
04/29/2013
13-27 PDF Image; Rule 1.73(a)(2)(iv); Interpretation
The Division of Clearing and Risk (DCR) provided an interpretation of whether the term "executing firm" in Regulation 1.73(a)(2)(iv) applies to introducing brokers, and the rule under Regulation 1.73(a)(2)(iv) of a futures commission merchant that provides to an introducing broker sponsored access to a market. The interpretation clarified that the term “executing firm” in Regulation 1.73(a)(2)(iv) refers to introducing brokers or futures commission merchants that execute orders for customers. The interpretation also clarified that an FCM that provides to an executing firm sponsored access to a market is not obligated under Regulation 1.73(a)(2)(iv), by virtue of the provision of such access, to conduct order screening of the executing firm’s customers.

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