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Part 4: CFTC Regulation 1.44—Key Definitions

The BR Derivatives Report

The previous post in this series discussed how different market participants hold different views of the relationship between an investment manager and its clients, particularly in the separate account context. That post concluded our discussion of background considerations in respect of proposed CFTC Regulation §1.44 (the “Proposed Rule”) and the related Margin Adequacy Requirement in respect of separate accounts.

This part begins a consideration of the provisions and conditions in the Proposed Rule, and related comments made by the U.S. Commodity Futures Trading Commission (“CFTC”).

This post will focus on two key definitions in the Proposed Rule:

  • “Account;” and
  • “Separate account.”

Other parts of this series will address other defined terms in the context of the specific provisions of the Proposed Rule in which those terms are used.

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