Tag: undermargined

Andrew P. Cross —

This post is the next in our multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”).

The previous post in this series focused on the relationship between international payment systems and timing considerations in the “one business day margin call requirement” that applies to separate account customers under the Proposed Rule.

This post explores four miscellaneous considerations related to this requirement. They are:

Andrew P. Cross —

This post is an overview of the “one business day margin call requirement” that applies to separate account customers under CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”).

The Proposed Rule seeks to balance the risk mitigation benefits of margin calls with practical limitations resulting from what the CFTC’s proposing release describes as “the mechanics of international payment systems (e.g., time zones and schedules of correspondent banks).”