The Division of Swap Dealer and Intermediary Oversight issued a “no-action” position from compliance with certain requirements of Regulation 1.57(a)(1), such that a guaranteed introducing broker could open and carry customer accounts with other than its guaranteeing futures commission merchant. Among other things, customers would be eligible contract participants and it was anticipated that the ultimate owner of the guaranteeing futures commission merchant would be the ultimate owner of an interest in the guaranteed introducing broker.