On July 13, the FIA issued a model disclosure form to assist futures commission merchants in complying with Regulation 1.71, a Commodity Futures Trading Commission rule that establishes information barriers between FCMs and affiliated swap dealers and major swap participants and requires FCMs to disclose to their customers conflicts of interest in the provision of trade execution or clearing services. The FIA noted that Regulation 1.71 was originally scheduled to become effective on June 4, 2012. The FIA Law & Compliance Division requested and obtained a 60-day extension of the disclosure statement requirement. The disclosure statement requirement therefore becomes effective on Aug. 3, 2012.
FIA Memo on CFTC Internal Conflict Rule – Model Disclosure Statement
FCM Conflicts Disclosure Statement
CFTC Response to Request for No-Action Relief from Provisions of Regulation 1.71
