Stephen Morris

Oct 23, 2024 | jdsupra.com | Stephen Morris

The back-office operations, finance and compliance teams of the futures commission merchant (FCM) clearing members of the CME Clearing House mark their calendars by the annual examination season. Overseen by the CME's Financial and Regulatory Surveillance Department, the annual financial and operational risk-based exam typically focuses on the FCM's margin processes, the accuracy and integrity of its financial statements, and its controls around customer asset protection.

Jul 22, 2024 | natlawreview.com | Stephen Morris

The CME has issued a revised Market Regulation Advisory Notice on Supervisory Responsibilities for Employees and Agents that includes a new “FAQ Related to Supervisory Responsibilities” (the “MRAN”). CME market participants – traders and intermediaries alike – will want to study the document closely.

Jul 3, 2024 | mondaq.com | Stephen Morris

The CME has issued a revised Market Regulation Advisory Notice on Supervisory Responsibilities for Employees and Agents that includes a new "FAQ Related to Supervisory Responsibilities" (the "MRAN"). CME market participants – traders and intermediaries alike – will want to study the document closely.

Jul 1, 2024 | lexology.com | Stephen Morris

The CME has issued a revised Market Regulation Advisory Notice on Supervisory Responsibilities for Employees and Agents that includes a new “FAQ Related to Supervisory Responsibilities” (the “MRAN”). CME market participants – traders and intermediaries alike – will want to study the document closely.

May 16, 2024 | natlawreview.com | Stephen Morris

Part 17 of the CFTC’s regulations require futures commission merchants, clearing members of registered derivatives clearing organizations, and foreign brokers holding omnibus accounts with such FCM clearing members to submit reports of the positions held by “large traders” (traders controlling positions exceeding thresholds prescribed under those regulations). For reporting firms, large trader reporting presents perhaps the most stubborn compliance challenge in the CFTC rulebook.