# CFTC Letter No. 19-21: No-action relief was granted to an entity from the statutory disqualification condition of CFTC Staff Letter No. 12-70 with repsect to its affiliate support activities

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CFTC_L19_21

## Section

- **Citation:** CFTC Letter No. 19-21
- **Heading:** No-action relief was granted to an entity from the statutory disqualification condition of CFTC Staff Letter No. 12-70 with repsect to its affiliate support activities
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CFTC Staff Letters (2008-present) / No-action relief was granted to an entity from the statutory disqualification condition of CFTC Staff Letter No. 12-70 with repsect to its affiliate support activities.

## Text

Summary: No-action relief was granted to an entity from the statutory disqualification condition of CFTC Staff Letter No. 12-70 with repsect to its affiliate support activities.

CFTC Letter No. 19-21 No-Action June 07, 2019

Division of Swap Dealer and

Matthew B. Kulkin
Director
Intermediary Oversight

Re:
No-Action Relief from the Statutory Disqualification Condition of
CFTC Staff Letter No. 12-70 regarding Affiliate Support Activities of
Firm “A”

Ladies and Gentlemen:

This letter is in response to your request to the Division of Swap Dealer and
Intermediary Oversight (“DSIO” or the “Division”) of the U.S. Commodity Futures
Trading Commission (“Commission” or “CFTC”) on behalf of Firm A for no-action
relief such that, if Firm A engages in any Affiliate Support Activities (as defined below)
on behalf of Affiliate “B” or Affiliate “C”, DSIO will not recommend an enforcement
action against Firm A or any of its employees for failure to register as an introducing
broker (“IB”) or commodity trading advisor (“CTA”) as required under section 4d(g) or
4m of the Commodity Exchange Act (“CEA”),1 respectively, based solely on the fact that
Firm A is subject to statutory disqualification under CEA section 8a(2) or 8a(3)2 due to
certain regulatory actions described below, provided that Firm A otherwise complies
with the conditions set forth in CFTC Staff Letter 12-70.3

I.
Statutory and Regulatory Background

Section 4d(g) of the CEA provides that it is unlawful for any person to be an IB unless
such person has registered with the Commission as an IB and such registration has not
expired or been suspended or revoked. Section 1a(31) of the CEA,4 as amended by the
Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank

1 CEA section 4d(g) is codified at 7 U.S.C. § 6d(g) and CEA section 4m is codified at 7
U.S.C. § 6m.
2 7 U.S.C
has registered with the Commission as an IB and such registration has not
expired or been suspended or revoked. Section 1a(31) of the CEA,4 as amended by the
Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank

1 CEA section 4d(g) is codified at 7 U.S.C. § 6d(g) and CEA section 4m is codified at 7
U.S.C. § 6m.
2 7 U.S.C. § 12a(2) & (3).
3 CFTC Ltr. 12-70 (Dec. 31, 2012), available at
http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/12-
70.pdf.
4 7 U.S.C. § 1a(31).
U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5000

Page 2

Act”),5 and Regulation 1.36 define the term, “introducing broker,” to include, inter alia,
any person who is engaged in soliciting or accepting orders for the purchase or sale of
any swap, provided that such person does not accept any money, securities or property
to margin, guarantee or secure any trades or contracts that result or may result
therefrom.

Section 4m of the CEA provides that it shall be unlawful for any CTA, unless registered
under the CEA, to make use of the mails or any means or instrumentality of interstate
commerce in connection with his business as such. Section 1a(12) of the CEA,7 as
amended by the Dodd-Frank Act, and Regulation 1.38 define the term, “commodity
trading advisor,” to include, inter alia, any person who, for compensation or profit,
engages in the business of advising others as to the value of or advisability of trading in
any swap. Regulation 4.69 excludes from the definition of CTA a registered swap dealer
(“SD”) and its employees and principals where the commodity interest and swap
advisory activities of the SD are solely incidental to the conduct of its business as an SD.
Regulation 4.1410 exempts from CTA registration a registered IB whose trading advice is
solely in connection with its business as an IB
any swap. Regulation 4.69 excludes from the definition of CTA a registered swap dealer
(“SD”) and its employees and principals where the commodity interest and swap
advisory activities of the SD are solely incidental to the conduct of its business as an SD.
Regulation 4.1410 exempts from CTA registration a registered IB whose trading advice is
solely in connection with its business as an IB.

Following implementation of the foregoing amendments to the IB and CTA definitions,
the Division received various registration no-action requests from affiliates of SDs who
are not registered with the Commission in any capacity (“Agent Affiliates”).

The requests stated, in pertinent part, that SDs may deal in swaps through multiple
affiliates, such that employees of an Agent Affiliate may engage in certain activities in
support of an affiliated SD (an “Affiliate SD Counterparty”) in connection with a
swap transaction to be entered by an Affiliate SD Counterparty. These activities may
include soliciting, negotiating, structuring, recommending, and/or accepting as agent,
swap transactions on behalf of the Affiliate SD Counterparty. Agent Affiliates may
receive compensation from an Affiliate SD Counterparty for services performed by their
employees by way of cost and/or revenue allocation arrangements. Because the Agent
Affiliates act only on behalf of Affiliate SD Counterparties that are already regulated by
the Commission and not unaffiliated third-parties, the Agent Affiliates argued that IB
and CTA registration was unnecessarily burdensome and requested relief from the IB
and CTA registration requirements.

5 Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. 111-203, 124
Stat. 1376 (2010). The text of the Dodd-Frank Act may be accessed through the
website of the Commission, www.cftc.gov.
6 17 C.F.R. § 1.3.
7 7 U.S.C. § 1a(12).
8 17 C.F.R. § 1.3.
9 17 C.F.R. § 4.6.
10 17 C.F.R. § 4.14.
and CTA registration requirements.

5 Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. 111-203, 124
Stat. 1376 (2010). The text of the Dodd-Frank Act may be accessed through the
website of the Commission, www.cftc.gov.
6 17 C.F.R. § 1.3.
7 7 U.S.C. § 1a(12).
8 17 C.F.R. § 1.3.
9 17 C.F.R. § 4.6.
10 17 C.F.R. § 4.14.

Page 3

In response to these requests, DSIO issued CFTC Staff Letter 12-70, stating that it would
not recommend that the Commission commence an enforcement action against an
Agent Affiliate or any employee thereof for failure to register as an IB or a CTA if such
Agent Affiliate engages in soliciting, negotiating, structuring, recommending, and/or
accepting as agent, swap transactions on behalf of an Affiliate SD Counterparty (the
“Affiliate Support Activities”), subject to the following conditions:


The Agent Affiliate is registered or licensed with, or subject to regulation by, a
financial services, prudential, or banking regulator (including a self-regulatory
organization) in specified jurisdictions (the “Regulated Entity Condition”);


The Agent Affiliate and the Affiliate SD Counterparty are “majority-owned
affiliates” as described in Regulation 1.3;11


The Agent Affiliate, the employee, and any person in the supervisory chain of
command of the employee, are not subject to statutory disqualification under
Sections 8a(2) and 8(a)(3) of the CEA (the “Statutory Disqualification
Condition”);


The Agent Affiliate and the employee provide commodity interest trading advice
in a manner solely incidental to the conduct of the business of the Agent Affiliate
for which it is subject to regulation under the Regulated Entity Condition and are
not engaged in any activity other than the Affiliate Support Activities that would
require registration as an IB, CTA or associated person (“AP”) thereof;


The Agent Affiliate and the Affiliate SD Counterparty execute in writing an
undertaking
incidental to the conduct of the business of the Agent Affiliate
for which it is subject to regulation under the Regulated Entity Condition and are
not engaged in any activity other than the Affiliate Support Activities that would
require registration as an IB, CTA or associated person (“AP”) thereof;


The Agent Affiliate and the Affiliate SD Counterparty execute in writing an
undertaking by which they each agree to be jointly and severally liable for any
violation of the CEA or Commission Regulations by any employee of the Agent
Affiliate engaged in any Affiliate Support Activity on behalf of the Affiliate SD
Counterparty, and the Agent Affiliate consents to the jurisdiction of the
Commission to investigate and take enforcement action against the Agent
Affiliate or any employee thereof engaged in any Affiliate Support Activity on
behalf of the Affiliate SD Counterparty for any violation of the CEA or
Commission
Regulations
by
such
employee
(the
“Joint
Liability
Undertaking”); and


The Affiliated SD Counterparty maintains the Joint Liability Undertaking at its
main business office and in accordance with Regulation 1.31.12

II.
Firm A’s Requests

Firm A represents that it wishes to rely on CFTC Letter No. 12-70 to engage in Affiliate
Support Activities on behalf of Affiliate B and Affiliate C (together, the “Affiliated

11 17 C.F.R. § 1.3.
12 17 C.F.R. § 1.31.
Joint Liability Undertaking at its
main business office and in accordance with Regulation 1.31.12

II.
Firm A’s Requests

Firm A represents that it wishes to rely on CFTC Letter No. 12-70 to engage in Affiliate
Support Activities on behalf of Affiliate B and Affiliate C (together, the “Affiliated

11 17 C.F.R. § 1.3.
12 17 C.F.R. § 1.31.

Page 4

SDs”), each of which has been provisionally registered with the Commission as SDs
since [ ]. All the relevant swaps would be executed in the name of, and booked at, one of
the Affiliated SDs. Firm A will not accept any money, securities or other property from
swap counterparties or the Affiliated SDs in connection with such swap transactions to
margin, guarantee or secure the obligations of any such counterparty or the Affiliated
SDs under any of the swap transactions. While all of Firm A’s employees engaged in
Affiliate Support Activities on behalf of the Affiliated SDs will be located in Foreign
Jurisdiction “Z”, the counterparties to certain of the swaps entered into by the Affiliated
SDs and intermediated by Firm A would be located in the United States.

Firm A is a broker-dealer incorporated in Foreign Jurisdiction Z and regulated by
Foreign Regulator “Y” and is not registered with the Commission in any capacity. Firm
A and the Affiliated SDs are wholly-owned subsidiaries of Group D, a banking and
financial services company formed under the laws of the United States (i.e., Firm A and
the Affiliated SDs are “majority-owned affiliates” as described in Regulation 1.3)
r incorporated in Foreign Jurisdiction Z and regulated by
Foreign Regulator “Y” and is not registered with the Commission in any capacity. Firm
A and the Affiliated SDs are wholly-owned subsidiaries of Group D, a banking and
financial services company formed under the laws of the United States (i.e., Firm A and
the Affiliated SDs are “majority-owned affiliates” as described in Regulation 1.3).

On XX, Foreign Regulator Y issued a[n] order (the “2019 Y Order”), finding that Firm
A violated the supervision requirements of Foreign Statute “X” because it failed to
establish and maintain a sufficient trading control system to prevent unfair trades in
connection with Foreign Jurisdiction Z government bond futures, including certain
spoofing activity by a former employee of Affiliate C in connection with certain Foreign
Jurisdiction Z government bond futures listed on the “W” Exchange.13 In this regard, it
is important to note that the spoofing activity occurred at an affiliate of Firm A in
Foreign Jurisdiction “U”, and was not the activity of an employee of Firm A in Foreign
Jurisdiction Z.

Because Foreign Statute X is similar to the CEA, the Securities Act of 1933, and the
Securities Exchange Act of 1934, the findings in the 2019 Y Order constitute grounds for
a statutory disqualification under Section 8a(3)(B) of the CEA.14 As a result, following
the issuance of the 2019 Y Order, Firm A would no longer be able to engage in Affiliate
Support Activities on behalf of Affiliated SDs in reliance on CFTC Letter No. 12-70 due
to failure to meet the Statutory Disqualification Condition.15

13 As a result of this former Affiliate C employee’s actions, Foreign Regulator Y ordered
Affiliate C to pay an administrative monetary penalty
rm A would no longer be able to engage in Affiliate
Support Activities on behalf of Affiliated SDs in reliance on CFTC Letter No. 12-70 due
to failure to meet the Statutory Disqualification Condition.15

13 As a result of this former Affiliate C employee’s actions, Foreign Regulator Y ordered
Affiliate C to pay an administrative monetary penalty.
14 Section 8a(3)(B) of the CEA provides that grounds for statutory disqualification exist
if a person has been found by a governmental body to have violated a statute of a
foreign jurisdiction that is similar to the Securities Act of 1933 or the Securities
Exchange Act of 1934, or any rule, regulation, or order under any such statute.
15 On [ ], the Division granted Firm A no-action relief similar to the relief provided in
this letter following the entering of [a] Commission Order [ ], which found that that
Firm A violated certain provisions of the CEA and imposed remedial sanctions on
Firm A, and Foreign Regulator Y entering two administrative orders against Firm A
in [ ] (together with the 2019 Y Order, the “Foreign Regulator Y Orders”). The
Division conditioned such relief on Firm A otherwise complying with the conditions
set forth in CFTC Letter No. 12-70 as well as additional conditions enumerated in the

Page 5

A.
Mitigating Circumstances Related to the 2019 Y Order

Firm A is aware that, in connection with an application to register an IB or CTA, the
Commission (or the National Futures Association (“NFA”), as its delegatee) may
exercise discretion to allow a person who would otherwise be statutorily disqualified
under Section 8a(2) or 8a(3) of the CEA to register with the Commission
notwithstanding such statutory disqualification. Firm A believes that it would be
appropriate for the Division to exercise similar discretion in the instant context by
providing relief from the statutory disqualification condition of CFTC Letter No. 12-70
subject to certain conditions
otherwise be statutorily disqualified
under Section 8a(2) or 8a(3) of the CEA to register with the Commission
notwithstanding such statutory disqualification. Firm A believes that it would be
appropriate for the Division to exercise similar discretion in the instant context by
providing relief from the statutory disqualification condition of CFTC Letter No. 12-70
subject to certain conditions. Firm A further notes that the Division adopted a similar
approach with respect to associated persons of a swap dealer, who likewise are not
subject to registration with the Commission but may be barred from conducting
Commission-regulated business as a result of a statutory disqualification.16

Firm A believes that there are several mitigating circumstances with respect to the 2019
Y Order that support granting the requested relief.17 First, Firm A notes that the
violation identified in the 2019 Y Order relates solely to deficiencies in Firm A’s existing
policies, procedures, systems, and controls, not fraud, manipulation or other intentional
misconduct.

Second, Firm A states that although the 2019 Y Order is connected to misconduct by an
employee of an affiliate of Firm A, namely, Affiliate C, that individual is no longer
employed by Affiliate C and no other employees have been found to have engaged in
misconduct. Thus, no individual who engaged in the spoofing activity is or will be an
employee of Firm A or engaged in Affiliate Support Activities covered by CFTC Letter
No. 12-70.

Third, Firm A indicates that system features developed by the vendor who provided
Firm A’s trade surveillance system resulted in the system not capturing trading activity
that took place after Friday evening and over the weekend, which contributed to Firm
A’s failure to detect spoofing activity.18 Firm A employees were not aware of the system
deficiency until the investigation corresponding to the 2019 Y Order occurred
at system features developed by the vendor who provided
Firm A’s trade surveillance system resulted in the system not capturing trading activity
that took place after Friday evening and over the weekend, which contributed to Firm
A’s failure to detect spoofing activity.18 Firm A employees were not aware of the system
deficiency until the investigation corresponding to the 2019 Y Order occurred. Firm A
has since learned that other firms who used the same trade surveillance system had the
same deficiency in their own systems.

no-action letter, including a duty to promptly notify Division staff of an event which
could constitute a statutory disqualification under Section 8a(2) or 8a(3) of the CEA
and, in the event of such disqualification, to cease to rely on the [ ] relief.
16 See CFTC Letter No. 12-15 (Oct. 11, 2012).
17 DSIO consulted with Foreign Regulator Y with respect to the 2019 Y Order and the
issuance of this letter.
18 With respect to detecting the spoofing activity, DSIO notes that such activity occurred
over a very short period from 7:45 PM on [XX] to 1:11 AM on [XX+1] and 7:16 PM on
[YY] to 1:02 AM on [YY+1].

Page 6

Fourth, Firm A notes that the 2019 Y Order is related to futures activities and does not
relate to swaps activities conducted by Firm A on behalf of the Affiliated SDs or
otherwise. Finally, Firm A states that it is improving, and will continue to strengthen,
its efforts to comply with the applicable Foreign Jurisdiction Z laws and regulations.

Lastly, the 2019 Y Order requires Firm A to take the following remedial actions (the
“Foreign Regulator Y Remedial Actions”):
oes not
relate to swaps activities conducted by Firm A on behalf of the Affiliated SDs or
otherwise. Finally, Firm A states that it is improving, and will continue to strengthen,
its efforts to comply with the applicable Foreign Jurisdiction Z laws and regulations.

Lastly, the 2019 Y Order requires Firm A to take the following remedial actions (the
“Foreign Regulator Y Remedial Actions”):

(1)
Clarify management’s stance with respect to compliance and appropriate
business operations, foster company-wide awareness of legal compliance and
sound corporate culture, and enhance and strengthen the management control
environment and internal control systems;

(2)
Prepare and establish an improvement plan based on the 2019 Y Order’s
findings, including measures for preventing recurrence of the misconduct
underlying the 2019 Y Order;

(3)
Verify the effectiveness of the measures taken pursuant to the business
improvement plan, and, if such measures are found to be inadequate, take
additional measures; and

(4)
With regard to (1) through (3) above, provide Foreign Regulator Y quarterly
written reports regarding implementation of such remedial measures.

In sum, Firm A believes that the lack of intentional misconduct, together with the
Foreign Regulator Y Remedial Actions, mitigate the regulatory concerns underlying the
Statutory Disqualification Condition because they minimize the extent to which Firm A’s
past violations are indicative of how it will behave in the future. Firm A has represented
that it is committed to continuing to conduct its business in full compliance with all
applicable regulatory obligations.

III.
Staff Position

Given the Commission Order and the Foreign Regulator Y Orders, Firm A could not
qualify for the relief under CFTC Staff Letter 12-70 due to the statutory disqualification
condition therein
how it will behave in the future. Firm A has represented
that it is committed to continuing to conduct its business in full compliance with all
applicable regulatory obligations.

III.
Staff Position

Given the Commission Order and the Foreign Regulator Y Orders, Firm A could not
qualify for the relief under CFTC Staff Letter 12-70 due to the statutory disqualification
condition therein. Notwithstanding that disqualification, the Division believes that a
time-limited no-action position is warranted in light of the reasons articulated by Firm
A above. Accordingly, until June 30, 2020, the Division will not recommend that the
Commission commence an enforcement action against Firm A or any employee of Firm
A for failure to register as an IB or CTA if Firm A or an employee of Firm A engages in
Affiliate Support Activities (as defined in CFTC Staff Letter 12-70) on behalf of the
Affiliated SDs, and complies with the following conditions:19

19 Conditions (1) through (5) mirror the ones in Part III of CFTC Staff Letter 12-70.

Page 7

(1)
Firm A is registered or licensed with, or subject to regulation by, Foreign
Regulator Y;
(2)
Firm A and the Affiliated SDs are “majority-owned affiliates” as described in
Regulation 1.3;20
(3)
Neither Firm A nor its employees engaged in Affiliate Support Activities on behalf
of the Affiliated SDs are subject to a statutory disqualification under Section
8a(2) or (3) of the CEA, and no person in the supervisory chain of command of
those relevant employees is subject to such a statutory disqualification, other
than solely as a result of the Commission Order or the Foreign Regulator Y
Orders;
(4)
Neither Firm A nor its employees are otherwise engaged in activity that would
require registration as IBs, CTAs or APs thereof;
tion under Section
8a(2) or (3) of the CEA, and no person in the supervisory chain of command of
those relevant employees is subject to such a statutory disqualification, other
than solely as a result of the Commission Order or the Foreign Regulator Y
Orders;
(4)
Neither Firm A nor its employees are otherwise engaged in activity that would
require registration as IBs, CTAs or APs thereof;
(5)
Firm A and each of the Affiliated SDs execute in writing an undertaking by which
they each agree to be jointly and severally liable for any violation of the CEA or
Commission Regulations by any employee of Firm A engaged in any Affiliate
Support Activity on behalf of an Affiliated SD; Firm A consents to the jurisdiction
of the Commission to investigate and take enforcement action against Firm A or
any employee of Firm A engaged in any Affiliate Support Activity on behalf of an
Affiliated SD for any violation of the CEA or Commission Regulations by such
employee; and the Affiliated SDs maintain such undertakings at their main
business offices and in accordance with Regulation 1.31;21
(6)
Firm A develops, implements, and follows policies and procedures reasonably
designed to monitor for and detect circumstances or events, including foreign
regulatory actions, that might constitute a statutory disqualification of Firm A
under Section 8a(2) or (3) of the CEA;
(7)
Such circumstances or events are promptly escalated to appropriate personnel for
a determination of whether such circumstance or event constitute a statutory
disqualification under Section 8a(2) or (3) of the CEA; and
d detect circumstances or events, including foreign
regulatory actions, that might constitute a statutory disqualification of Firm A
under Section 8a(2) or (3) of the CEA;
(7)
Such circumstances or events are promptly escalated to appropriate personnel for
a determination of whether such circumstance or event constitute a statutory
disqualification under Section 8a(2) or (3) of the CEA; and
(8)
If it is determined that Firm A is subject to a statutory disqualification under
Section 8a(2) or (3) of the CEA, other than solely as a result of the Commission
Order or the Foreign Regulator Y Orders, Firm A will promptly notify Division
staff and cease to rely on this letter.
Failure to comply with any of the conditions of this letter, the undertakings of the
Commission Order, or the Foreign Regulator Y Remedial Actions will automatically
terminate the relief granted herein. The Division further wants to emphasize that this
no-action position with respect to the Statutory Disqualification Condition only applies
to Firm A and its employees in connection with the specific facts and circumstances
outlined in this letter. The Division is not, with this letter, granting any other person
relief concerning the statutory or regulatory provisions governing persons who are
subject to statutory disqualification.

20 17 C.F.R. § 1.3.
21 17 C.F.R. § 1.31.
s
to Firm A and its employees in connection with the specific facts and circumstances
outlined in this letter. The Division is not, with this letter, granting any other person
relief concerning the statutory or regulatory provisions governing persons who are
subject to statutory disqualification.

20 17 C.F.R. § 1.3.
21 17 C.F.R. § 1.31.

Page 8

This letter, and the positions taken herein, represent the view of the Division only, and
do not necessarily represent the position or view of the Commission or of any other
office or division of the Commission. The relief issued by this letter does not excuse
Firm A or its employees from compliance with any other applicable requirements
contained in the CEA or in the Commission Regulations issued thereunder. For
example, Firm A remains subject to all antifraud provisions of the CEA.22 Further, this
letter, and the relief contained herein, is based upon the representations made to the
Division. Any different, changed or omitted material facts or circumstances might
render this letter void.

Should you have any questions, please contact me at (202) 418-5326, Frank Fisanich,
Chief Counsel, at (202) 418-5949, or Gregory Scopino, Special Counsel, at (202) 418-
5175.

Very truly yours,

Matthew B. Kulkin
Director
Division of Swap Dealer and Intermediary Oversight

Cc:
Regina Thoele, Compliance

National Futures Association, Chicago

Jamila A. Piracci, OTC Derivatives

National Futures Association, New York

22 See, e.g., sections 4b and 4o of the CEA. 7 U.S.C. §§ 6b & 6o.

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- [CFTC Letter No. 09-07 The CPO of a commodity pool with a de minimus amount of its assets embroiled in a bankruptcy requested relief from the ongoing reporting requirements under Part 4. The CPO filed an Annual Report for the Pool for the 2...](https://www.frixlaw.com/law-library/statutes/CFTC_L09_07.md)
- [CFTC Letter No. 09-11 The CPO of two commodity pools requested relief to use IFRS in lieu of US GAAP. DCIO granted relief pursuant to Commission Regulations 140.93 and 4.12(a).](https://www.frixlaw.com/law-library/statutes/CFTC_L09_11.md)
- [CFTC Letter No. 09-13 The CPO of commodity pool requested relief to use IFRS in lieu of US GAAP. DCIO granted relief pursuant to Commission Regulations 140.93 and 4.12(a).](https://www.frixlaw.com/law-library/statutes/CFTC_L09_13.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFTC_L19_21. Check the current official text before relying on it. Not legal advice.