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Part 3: Separate Accounts and CFTC Regulation §1.44—Different Views of the Same Situation

The BR Derivatives Report

This is the next installment of our multi-part series on the February 20 proposal by the U.S. Commodity Futures Trading Commission (the “CFTC”) in respect of proposed CFTC Regulation §1.44 (the “Proposed Rule”).

The previous post provided general information about the nature of the relationship between institutional investors and their investment managers. Indeed, that relationship was one of the primary reasons for the Proposed Rule.

This post considers different views of the relationship between an investment manager and its clients, as background to a discussion of the Proposed Rule.

Some market participants and commenters view the Proposed Rule as creating risk, while others view the Proposed Rule as a necessary nuisance. In short, different market participants have different views of the same situation.

To read the full post, please visit our BR Derivatives Report blog.