Staff of the Division of Clearing and Risk (“DCR”), Division of Market Oversight (“DMO”), and Market Participants Division (“MPD”) (collectively, the “Divisions”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”) are issuing this advisory to set forth CFTC staff’s expectations with respect to, designated contract markets (“DCMs”), swap execution facilities (“SEFs”), and derivatives clearing organizations (“DCOs”) who are seeking to extend trading and/or clearing operations to a 24 hours a day, 7 days a week (“24/7”) basis as well as futures commission merchants (“FCMs”) seek

Interpretation of the Commodity Exchange Act and Commission regulations regarding the characterization of variation margin payments and all other cash flows for cleared swaps.

North American Derivatives Exchange, Inc. (Nadex) requested interpretative guidance concerning certain provisions of the Commission’s Part 39 regulations applicable to derivatives clearing organizations due to the unique nature of Nadex’s business model.