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      Course Overview

      Overview

      • CME Group Rules and Regulation Overview
      • Market Regulation: Meet the Team

      Wash Trades

      • Wash Trades - Definition of a Wash Trade
      • Wash Trades – Responsibility and Implications
      • Wash Trades – Automated Trading Systems
      • Wash Trades - Freshening

      EFRP

      • EFRP - What is an EFRP?
      • EFRP - Parties to an EFRP
      • EFRP - Pricing and the Related Position for EFRPs
      • EFRP - Reporting and Recordkeeping
      • EFRP - Prohibited Transitory EFRPs

      Block Trades

      • Block Trades - What is a Block Trade?
      • Block Trades – Participant Eligibility
      • Block Trades – Eligible Products, Times and Prices
      • Block Trades – Reporting and Recordkeeping
      • Block Trades – Pre-Hedging
      • Block Trades – TAS, TAM and BTIC

      Disruptive Practices Prohibited

      • Disruptive Practices Prohibited - General Information
      • Disruptive Practices Prohibited - Factors Market Regulation Considers
      • Disruptive Practices Prohibited - Spoofing
      • Disruptive Practices Prohibited - Flipping
      • Disruptive Practices Prohibited - Additional Examples
      • Disruptive Practices Prohibited - Frequently Asked Questions

      CME Globex Operator ID Requirements

      • CME Globex Operator ID Requirements – General Rule
      • CME Globex Operator ID Requirements - Registration and Requirements
      • CME Globex Operator ID Requirements - Individual and Team Operators

      Pre-Execution Communications

      • Pre-Execution Communications - Overview & Crossing Protocols

      Rule 524 - TAS, TAM, BTIC and TACO

      • Rule 524 - TAS, TAM, BTIC, and TACO

      Enforcement Process

      • Enforcement Process - Introduction and Initial Referral
      • Enforcement Process - Offer of Settlement
      • Enforcement Process - Settlement Hearing
      • Enforcement Process - Default Hearings
      • Enforcement Process - Contested Hearings
      • Enforcement Process - Appeals
      Market Regulation
      You completed this course.Get Completion Certificate

      EFRP - Reporting and Recordkeeping

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      Submitting EFRPs to the CME Clearing House

      Exchange for Related Positions (EFRP) must be submitted to CME Clearing via CME Direct or CME ClearPort.

      An EFRP transaction submitted to CME Clearing is not considered to have been accepted until the transaction has cleared and the first payment of settlement variation and performance bond has been confirmed.

      Remember that the date and time of execution must be accurately submitted for each EFRP transaction, in the local time of the party(ies) entering the EFRP.

      How Long Do I Have to Submit an EFRP for Clearing?

      EFRP transactions should be submitted to the exchange as soon as possible following agreement to the relevant terms by the parties to the trade. The Market Regulation Department expects submission to occur the same day that the EFRP is executed, absent extenuating circumstances.

      The relevant terms of the EFRP are considered to have been determined at the time the price and quantity of the exchange contract and the corresponding related position component of the transaction are agreed upon by the parties to the EFRP. However, where the actual delivery quantity may not be precisely determined by the parties until the time of delivery, the parties may contractually agree to submit the transaction to CME Clearing within the required reporting period following the time at which the actual delivery quantities are determined, rather than reporting the EFRP at the time of pricing. Absent such contractual arrangement, the transaction must be reported at the time of pricing.

      Notwithstanding any of the foregoing, EFRPs may not under any circumstances be submitted for clearing later than the end of the permissible posting period that follows the expiration of the futures contract. These times are specified in the relevant product chapters of the applicable exchange rulebook.

      Recordkeeping

      Parties to an EFRP transaction must maintain all records relevant to the exchange contract and the related position transaction. Some of the required record include:

      • Order tickets
      • Records reflecting payments between the parties
      • Transfer of title (where appropriate)
      • Records customarily generated in accordance with relevant market practices
      • Any other records required to be kept pursuant to CFTC Regulations

      Upon request, such records must be provided to Market Regulation in a timely manner. It is the carrying clearing member firm’s responsibility to obtain and submit the requested records of their clients to the exchange on a timely basis.

      In addition, parties who facilitate EFRP transactions must maintain all records corresponding to their facilitation of the transactions.

      Responsibilities of Firms

      Firms that execute or clear EFRPs on behalf of customers are responsible for ensuring that their customers are fully informed regarding exchange EFRP requirements. Upon request by the Market Regulation Department, firms carrying accounts that execute EFRPs are responsible for obtaining and submitting records of their clients’ EFRP transactions in a timely and complete manner.

      Further, firms that execute or clear EFRPs on behalf of customers should exercise due diligence in identifying circumstances in which a customer’s EFRP transactions may be non-bona fide.

      This is part of a course on EFRPs. For official regulatory guidance on EFRPs, reference the applicable Market Regulation Advisory Notice.


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