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April 25, 2007
CFTC and FinCEN Issue Guidance on CIP Requirements with Respect to Give-up Arrangements
On April 20, 2007, the CFTC and FinCEN issued joint guidance on the application of the customer identification program (CIP) requirements to give-up arrangements in the futures industry. The guidance clarifies that in a give-up arrangement, the clearing FCM establishes the formal relationship with the customer for purposes of the CIP requirements. As a result, the clearing FCM, and not an FCM acting solely as an executing broker in a give-up arrangement, is required to apply their CIP to the customer. The full text of this guidance can be found at http://www.fincen.gov/cftc_fincen_guidance.pdf.