18-31
Title: 18-31
Conditional No-Action Relief to Eurex Clearing AG and its FCM Clearing Members to hold customer margin in the form of securities at Clearstream Banking AG
Conditional No-Action Relief to Eurex Clearing AG and its FCM Clearing Members to hold customer margin in the form of securities at Clearstream Banking AG
Interpretation of the Commodity Exchange Act and Commission regulations regarding the characterization of variation margin payments and all other cash flows for cleared swaps.
No-action position of DSIO with respect to withdrawals of residual interest related to margin deficits prior to required segregation computation under Commission Regulation 22.17(b).
Extension of Time-Limited No-Action relief from compliance with certain conditions associated with the receipt of customer funds by FCMs.
Extension of no-action relief from compliance with certain conditions associated with the receipt of customer funds by FCMs.
Staff issued an interpretation providing that a futures commission merchant (FCM) may credit a customer’s trading account for a margin payment upon the FCM’s initiation of a withdrawal from the customer’s bank account using the Automated Clearing House (ACH) payment processing system. The FCM also may consider such pending margin payments in computing its regulatory capital.
No-action relief from compliance with certain conditions associated with the receipt of customer funds by FCMs.
Division of Clearing and Risk staff issued an interpretation providing clarification that while regulation 22.2(d) prohibits an FCM from permitting a lien on Cleared Swaps Customer Collateral that it holds, regulation 22.2(d) does not prohibit a Cleared Swaps Customer from granting a lien on his or her own account at the FCM, nor does the regulation prohibit the FCM from taking action to foster the Cleared Swaps Customer’s grant of such a lien.