The Division of Clearing and Intermediary Oversight issued an IB registration no-action position to a United States bank whose foreign branches wish to refer foreign customers to an affiliated registered FCM. This position was based in part on the branches being located outside the United States and the FCM accepting liability for the foreign branches.

DCIO responded to a request for guidance from the Joint Audit Committee (JAC) as to investments of customer funds by futures commission merchants (FCMs) in corporate debt securities guaranteed by the Federal Deposit Insurance Corporation (FDIC) under its Temporary Liquidity Guarantee Program (TLGP).

DCIO received a request for guidance from the Joint Audit Committee concerning FCM regulatory reporting requirements for investments in a money market mutual fund. The fund had announced that its net asset value per share had fallen from $1.00 and that, as permitted by order of the SEC dated September 22, 2008, the fund had suspended redemptions and postponed payments.