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Interpretative Letters

Interpretative Letters
07-14 PDF Image; Regulation 1.33; Interpretation
The Division of Clearing and Intermediary Oversight provided an Interpretation that a registered futures commission merchant ("FCM") would be in compliance with Regulation 1.33, which requires an FCM to furnish its customers certain Account Statements, where the customer has been provided electronic access via a password-protected website to the information required to be transmitted. This relief is subject to conditions that the FCM: (1) receive a written statement from the customer acknowledging and agreeing to the foregoing arrangement; and (2) promptly furnish to the customer, upon its request, paper versions of the customer’s Account Statements.
07-22 PDF Image; Commission Regulation 4.22; Commission Regulation 1.16; Interpretation
Multi-columnar financial statements were acceptable for a commodity pool series fund organized as a Delaware statutory trust in compliance with generally accepted accounting principles as the series fund complied with requirements necessary to maintain an inter-series limitation on liability and received an unqualified audit opinion.
07-24 PDF Image; Regulation 1.12(h), 1.20 and 1.25; Interpretation
Response to query from a designated self-regulatory organization regarding whether notice under 1.12(h) is required in connection with an investment of customer funds that complies with the segregation requirements of Section 4d and Commission Regulation 1.20, but does not meet all of the requirements in Commission Regulation 1.25.

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