1 September 2017
By MarketVoice Staff
On Sept. 22, the European Commission published two separate Delegated Regulations on indirect clearing arrangements. An indirect clearing arrangement refers to a set of relationships where at least two intermediaries are interposed between an end-client and the relevant central counterparty. The aim of the texts is to:
To help member firms in the U.S. comply with the new indirect clearing rules, FIA has published a memo reviewing the compliance obligations created by these rules and the conflicts with certain aspects of U.S. rules and regulations. The memo, which was prepared by the law firm of Katten Muchin Rosenman, identifies circumstances in which the requirements of the U.S. Bankruptcy Code, the Commodity Exchange Act and/or the regulations of the Commodity Futures Trading Commission may prohibit futures commission merchants from complying with such obligations.
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