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The CFTC's Division of Swap Dealer and Intermediary Oversight issued interpretative guidance stating that a futures commission merchant (FCM), swap dealer (SD), ...
The CFTC's Division of Swap Dealer and Intermediary
Oversight issued interpretative guidance stating that a futures
commission merchant (FCM), swap dealer (SD), or introducing broker
(IB) that receives separate compensation for commodity trading
advice is not required to register as a commodity trading advisor,
provided that the offered advice is "solely incidental"
to the conduct of the FCM's or SD's business, or
"solely in connection with" the operation of the IB's
business. The guidance was requested in response to the European
Union's MiFID II Directive, but it also extends to separate
payments for commodity trading advice received by FCMs, SDs and IBs
outside of the requirements of the MiFID II Directive.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
