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ARTICLE · 21 SEPTEMBER 2020

CFTC Staff Revises Margin Treatment For Separate Accounts

Hogan Lovells Cadwalader
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Credit risk to an intermediary is a real concern.

United StatesFinance and Banking
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The Division of Clearing and Risk and the Division of Swap Dealer and Intermediary Oversight (the "Divisions") provided further relief and guidance concerning the treatment of separate accounts of a single beneficial owner by futures commission merchants ("FCMs").

The new relief (CFTC Letter 20-28) comes in response to an inquiry from FIA requesting an extension of relief previously granted in CFTC Letter 19-17 (see previous coverage) and clarified in a further staff statement (see previous coverage). The prior relief was set to expire on September 15, 2020, but the new relief extends the expiration date to March 31, 2021, which the Divisions state is "due only to the extraordinary difficulties created by the COVID-19 Pandemic."

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