• Block Trades

      • To
      • Members, Member Firms and Market Users
      • From
      • Market Regulation Department
      • #
      • CME & CBOT RA1110-3
      • Notice Date
      • 05 December 2011
      • Effective Date
      • 05 December 2011
    • Effective immediately, this Advisory Notice supersedes CME & CBOT Market Regulation Advisory Notice RA1109-3 issued on October 3, 2011. It is being issued to remove CME Nonfarm Payroll futures and options from the list of block-eligible products based on today’s delisting of those products. 
      CME and CBOT products in which block trading is permitted appear in Section 10 and the text of CME and CBOT Rule 526 appears in Section 12 of this Advisory Notice.
      1.         Definition of Block Trades
       
      Block trades are privately negotiated futures, options or combination transactions that meet certain quantity thresholds which are permitted to be executed apart from the public auction market. All block trades are subject to the conditions set forth in CME and CBOT Rule 526 (“Block Trades”) and in this Advisory Notice.
       
      2.         Participation in Block Trades
       
      Each party to a block trade must be an Eligible Contract Participant as that term is defined in Section 1a(12) of the Commodity Exchange Act. Eligible Contract Participants generally include exchange members and member firms, broker/dealers, government entities, pension funds, commodity pools, corporations, investment companies, insurance companies, depository institutions and high net-worth individuals. Commodity trading advisors and investment advisors who are registered or exempt from registration, and foreign persons performing a similar role and subject as such to foreign regulation, may participate in block transactions provided they have total assets under management exceeding $25 million and the block trade is suitable for their customers.
       
      A customer order may be executed by means of a block trade only if the customer has specified that the order be executed as a block trade.
       
      Orders may not be bunched to meet the minimum block quantity thresholds.
       
      3.         Time and Prices of Block Trades
       
      Block trades may be executed at any time, including times during which the public auction market is closed. 
       
      Block trades must be transacted at prices that are “fair and reasonable” in light of (i) the size of the transaction, (ii) the prices and sizes of other transactions in the same contract at the relevant time, (iii) the prices and sizes of transactions in other relevant markets, including, without limitation, the underlying cash market or related futures markets, at the relevant time, and (iv) the circumstances of the markets or the parties to the block trade.
       
      The trade price must be consistent with the minimum tick increment for the market in question. Additionally, each outright transaction and each leg of any block eligible spread or combination trade must be executed at a single price. 
       
      Block trade prices are reported independently of transaction prices in the regular market and are not included as part of the daily trading range. Block trade prices do not elect conditional orders (e.g. stop orders) or otherwise affect orders in the regular market. 
       
      4.         Block Trade Minimum Quantities for Outrights, Spreads and Combinations
       
      The block trade minimum quantity requirements for outright futures and options are set forth in the list of block trade eligible products in Section 10 of this Advisory Notice. Additional information with respect to spreads and combinations executed as blocks appears below. 
       
      a) Intra-Commodity Futures Spreads and Futures Combinations
       
                  i) All Products Excluding U.S. Treasury, OTR Treasury Yield, Interest Rate Swap and GSCI Futures
       
      Intra-commodity futures spreads and futures combinations may be executed as block trades provided that the sum of the quantities of the legs meets the minimum block quantity threshold. For example, 2,000 Eurodollar future calendar spreads executed during RTH hours would meet the Eurodollar futures minimum quantity requirement of 4,000 contracts.
       
                  ii) U.S. Treasury, OTR Treasury Yield and Interest Rate Swap Futures
       
      Intra-commodity calendar spread block trades are prohibited in CBOT U.S. Treasury futures, OTR Treasury Yield and Interest Rate Swap futures. Parties may not execute contingent block trades in outright contracts to circumvent the prohibition on the execution of block trades in intra-commodity calendar spreads. Additionally, Tandem spreads may not be executed as block trades.   
       
                  iii) GSCI Futures
       
      In GSCI futures and GSCI Excess Return Index futures the block trade minimum is 300 contracts for each leg of the spread or combination. For example, the minimum quantity for a GSCI calendar spread would require 300 contracts in each leg of the spread for a total of 600 contracts while a GSCI futures butterfly would require a minimum volume of 1,200 contracts.
       
      b) Inter-Commodity Futures Spreads
       
                  i) Short Term Interest Rate Futures
       
      In Short Term Interest Rate futures (Eurodollars, Eurodollar E-minis, Euribor, T-Bills, OIS, One-Month Eurodollar, Euroyen and 30-Day Fed Funds), inter-commodity futures spreads may be executed as block trades provided that the sum of the legs of the spread meets the larger of the threshold requirements for the underlying products. For example, the minimum quantity thresholds for One-Month Eurodollar and Eurodollars during ETH are 200 and 2,000 contracts, respectively. Therefore, a block trade in the One-Month Eurodollar/Eurodollar spread can be executed provided that the sum of the legs is at least 2,000 contracts. 
       
                  ii) U.S. Treasury, OTR Treasury Yield, Interest Rate Swap and 10-Year Sovereign Yield Spread Futures
       
      In U.S. Treasury, OTR Treasury Yield, Interest Rate Swap and 10-Year Sovereign Yield Spread futures, inter-commodity futures spreads may be executed as block trades provided that each leg of the spread meets the minimum threshold requirement for the respective underlying products. For example, the minimum quantity thresholds for 10-Year Notes and U.S. Treasury Bonds during RTH are 5,000 and 3,000 contracts, respectively. Therefore, a block trade in the NOB spread (10-Year Note/Treasury Bond spread) can be executed only if the minimum quantity of the 10-Year Note leg of the spread is at least 5,000 contracts and the minimum quantity of the Treasury Bond leg of the spread is at least 3,000 contracts.
       
                  iii) All Other Products
       
      In all other block-eligible products, inter-commodity futures spreads may be executed as block trades provided that the quantity of each leg of the spread meets the larger of the threshold requirements for the underlying products. 
       
      c) Intra-Commodity Option Spreads and Combinations
       
      Intra-commodity option spreads and combinations may be executed as block trades provided that the quantity of each leg of the spread meets the designated minimum quantity threshold.
       
      d) Inter-Commodity Option Spreads and Combinations
       
      Inter-commodity option spreads and combinations may be executed as block trades provided that the quantity of each leg of the spread meets the larger of the threshold requirements for the underlying products.
       
      e) Options/Futures Spreads
       
      In general, options/futures spreads may be executed as block trades provided that the options component of the spread meets the minimum quantity threshold for the outright option or option combination and the quantity of futures executed is consistent with the delta of the options component of the spread. An exception applies to Weather, Real Estate and Non-Farm Payroll options/futures spreads, where the legs of the spread may be summed to meet the 20-contract minimum threshold.
       
      5.         Block Trade Reporting Requirements
       
      a) Time Requirements
       
      i) Interest Rate Block Trades
       
      Block trades must be reported to the Exchange by the seller within five minutes of the transaction for block trades executed during RTH and within fifteen minutes of the transaction for block trades executed during ETH and ATH. For purposes of interest rate block trades, RTH, ETH and ATH are defined in Section 10 of this Notice.
       
      ii) Other Block Trades Excluding Interest Rates, Weather and Housing Block Trades
       
      Block trades must be reported to the Exchange by the seller within five minutes of the transaction.
       
       
       
      iii) Weather and Housing Block Trades
       
      Block trades must be reported to the Exchange by seller within fifteen minutes of the transaction. 
       
      b) Reporting Methods
       
      Block trades must be reported to the Exchange via one of the following methods.
       
      i) Globex Control Center (“GCC”)
       
      All block trades (except for block trades in Weather futures and options executed between 8:00 a.m. and 3:30 p.m. Chicago time, Monday – Friday on regular business days – see subsection iv below) may be reported to the GCC. The seller reports the trade by calling the GCC at 312.456.2391. When the GCC is closed – for example, during the weekend – the block trade must be reported no later than five minutes prior to the opening of the next electronic trading session for that product.
       
                  ii) CME ClearPort
       
      Block trades may be electronically reported directly to CME Clearing via CME ClearPort. For information on reporting block trades through CME ClearPort, please contact customer service at 1.800.438.8616 or via email at ClearPort@cmegroup.com.
       
      iii) CME Clearing360 Trade Reporter
       
      Block trades may be electronically reported directly to CME Clearing via CME Clearing360 Trade Reporter, available through the CME EOS Trader web-based front end. For additional information on reporting block trades via CME Clearing360 Trade Reporter, please visit http://cmegroup.com/clearing/trading-practices/cme-clearing360-tradereporter.html or contact CME Clearing Customer Support at 312.207.2525 or via email at CCS@cmegroup.com .
       
      iv) Weather Blocks on CME Clearing360 via Pivot Instant Markets
       
      Block trades in Weather futures and options may be electronically reported directly to CME Clearing360 via Pivot Instant Markets by eligible inter-dealer brokers. For additional information on reporting block trades via Pivot Instant Markets, please contact Angie DiCarlo, Associate Director, CME Group Alternative Investments at 312.930.4515 or via email at Angie.DiCarlo@cmegroup.com.
       
      v) Weather Block Trades Executed Between 8:00 a.m. and 3:30 p.m.
       
      Block trades in Weather futures and options executed between 8:00 a.m. and 3:30 p.m. Chicago time, Monday – Friday on regular business days should be reported to Exchange staff by calling 312.648.3935 or 312.648.3936.
       
      When reporting a block trade, the following information will be required:
       
      • Name and phone number of the clearing firm representative reporting the trade (unless the block trade is electronically reported);
      • Buyer’s clearing firm and seller’s clearing firm;
      • Contract, contract month and contract year for futures;
      • Contract, contract month, contract year, strike price and put or call designation for standard options, as well as the expiration date and exercise style for flex options;
      • Quantity of the trade or, for spreads and combinations, the quantity of each leg of the trade;
      • Price of the trade or, for spreads and combinations, the price of each leg of the trade; and
      • Execution time (in Central Time) of the trade (i.e. the time at which the trade was consummated).
      6.         Block Trade Submission Requirements to CME Clearing
       
      Block trades reported to the GCC or Exchange staff as described in numbers i) or v) above must be submitted to CME Clearing through the Front-End Clearing (“FEC”) User Interface via the portal under BLOCK entry. For block trades executed between 6:00 a.m. and 6:00 p.m. Central Time, firms must submit the trade within one hour. For block trades executed between 6:00 p.m. and 6:00 a.m. Central Time, firms must submit the trade no later than 7:00 a.m. Central Time.
       
      Block trades are entered by both the buyer’s and seller’s clearing firm and go through a two-sided match process. Upon entry, confirmation records will be routed back to the firms for bookkeeping purposes. When reporting spread or combination transactions, each leg must be entered individually. The execution time is required to be entered and must be the actual time at which the transaction was consummated by the two parties, not the time at which the trade is reported by the parties to their respective firms. Thus, if the clearing member has not acted as either principal or agent in the transaction, it must ensure that its customer provides an accurate execution time.
       
      A block trade in a block-eligible option may be executed up to and including the day on which an option contract expires for purposes of offsetting an open option position. The offsetting block trade must be reported to the GCC pursuant to the requirements of section 4 above, and the offset must be reported to CME Clearing no later than the Position Change Submission (“PCS”) deadline on the day on which the option contract expires. The current PCS deadline is 7:30 p.m. Central Time.
       
      7.         Block Trade Recordkeeping
       
      Complete order records for block trades must be created and maintained pursuant to Rule 536 and CFTC Regulations. However, as noted in Section 5, the time of execution of the block trade must also be recorded.
       
      8.         Dissemination of Block Trade Information
       
      The date, execution time, contract details, price and quantity of block trades are reported upon receipt of the block information by GCC. Block trade information is reported on the MerQuote system and may be accessed by entering the code “BLK”. The information will also be displayed on cmegroup.com at the following link: http://www.cmegroup.com/tools-information/blocktrades.html. Block trade information is also displayed on the trading floor.
       
      Block trade prices are published separately from transactions in the regular market. Block trade volume is also included with other privately negotiated transactions in the daily volume reports published by the exchange.
       
      9.         Pre-Execution Communications
       
      The prohibition on prearranged trading and the requirements related to pre-execution communications with respect to certain Globex trades set forth in Rule 539 do not apply to block trades.
       
      10.        CME & CBOT Block Trade-Eligible Products
       
      For purposes of the interest rate products in the tables, the following times apply:
       
      ETH:   12:00 a.m. – 7:00 a.m. CT, Monday through Friday on regular business days
      RTH:   7:00 a.m. – 4:00 p.m. CT, Monday through Friday on regular business days
      ATH:   4:00 p.m. – 12:00 a.m. CT, Monday through Friday on regular business days and at all times on weekends

      CME Products

       
              Futures
         Options
      Flex Options
      Eurodollars (RTH)
      4,000 contracts - or 1,000 contracts provided that a minimum of 1,000 contracts are transacted in yrs 6-10
      10,000 contracts
      Not Available
      Eurodollars (ETH)
      2,000 contracts – or 500 contracts provided that a minimum of 500 contracts are transacted in yrs 6-10
      5,000 contracts
      Not Available
      Eurodollars (ATH)
      1,000 contracts – or 250 contracts provided that a minimum of 250 contracts are transacted in yrs 6-10
      2,500 contracts
      Not Available
      Eurodollar E-mini futures (RTH)
      40,000 contracts
      Not available
      Not available
      Eurodollar E-mini futures (ETH)
      20,000 contracts
      Not available
      Not available
      Eurodollar E-mini futures (ATH)
      10,000 contracts
      Not available
      Not available
      3-Month Overnight Index Swaps (OIS)(RTH)
      2,000 contracts
      Not available
      Not available
      3-Month Overnight Index Swaps (OIS)(ETH)
      1,000 contracts
      Not available
      Not available
      3-Month Overnight Index Swaps (OIS)(ATH)
      500 contracts
      Not available
      Not available
      3-Month OIS/Eurodollar spread (RTH)
       
      4,000 contracts (all legs combined)
      Not available
      Not available
      3-Month OIS/Eurodollar spread (ETH)
       
      2,000 contracts (all legs combined)
      Not available
      Not available
      3-Month OIS/Eurodollar spread (ATH)
       
      1,000 contracts (all legs combined)
      Not available
      Not available
      T-Bills (RTH)
      100 contracts
      Not available
      Not available
      T-Bills (ETH)
      50 contracts
      Not available
      Not available
      T-Bills (ATH)
      25 contracts
      Not available
      Not available
      Euroyen (RTH)
      200 contracts
      200 contracts
      Not available
      Euroyen (ETH)
      100 contracts
      100 contracts
      Not available
      Euroyen (ATH)
      50 contracts
      50 contracts
      Not available
      One-Month Eurodollar (RTH)
      400 contracts
      400 contracts
      Not available
      One-Month Eurodollar (ETH)
      200 contracts
      200 contracts
      Not available
      One-Month Eurodollar (ATH)
      100 contracts
      100 contracts
      Not available
      10-Year Sovereign Yield Spread
      250 contracts
      Not available
      Not available
      Three-Month Euribor
      2,000 contracts (nearest 20 March quarterly cycle delivery months and non-March quarterly cycle delivery months)
       
      500 contracts (farthest 20 March quarterly cycle delivery months)
      Not available
      Not available
      Barclays Capital U.S. Aggregate Bond Index
      50 contracts
      Not available
      Not available
      Eurozone Harmonized Index of Consumer Prices (HICP)
      50 contracts
      Not available
      Not available
      CME Products
              Futures
         Options
      Flex Options
      S&P 500*
      Not available
      250 contracts
      250 contracts
      NASDAQ-100*
      200 contracts - outrights only
      100 contracts
      100 contracts
      S&P SmallCap 600, E-mini S&P SmallCap 600, E-mini NASDAQ Composite Index, E-mini S&P Select Sector Stock Index
      50 contracts
      Not available
      Not available
      E-mini S&P CNX Nifty Index
      50 contracts
      Not available
      Not available
      E-micro S&P CNX Nifty Index
      250 contracts
      Not available
      Not available
      TRAKRS Indexes
      100,000 contracts
      Not available
      Not available
      S&P MidCap 400*, S&P 500/Citigroup Growth, S&P 500/Citigroup Value, Nikkei  225
      50 contracts
      250 contracts
      250 contracts
      Custom Stock Index/SGI Wise US
      50 contracts
      Not Available
      Not available
      Goldman Sachs Commodity Index (GSCI), GSCI Excess Return Index
      50 contracts for outrights – 300 contracts for each leg
      of a spread transaction
      Not available
      Not available
      International Skimmed Milk Powder
      20 contracts
      Not available
      Not available
      EUR/USD 1-Month and 3-Month Realized Volatility
      50 contracts
      Not available
      Not available
      EUR/USD*, JPY/USD*
      150 contracts
      250 contracts
      Not available
      AUD/USD, CAD/USD, CHF/USD, GBP/USD, MXN/USD
      100 contracts
      250 contracts
      Not available
      EUR/GBP, EUR/CHF, EUR/JPY, NZD/USD, BRL/USD, CZK/USD, CZK/EUR, HUF/EUR, HUF/USD, ILS/USD, KRW/USD, PLN/USD, PLN/EUR, RMB/USD, RMB/EUR, RMB/JPY, RUB/USD, ZAR/USD, USD/TRY, EUR/TRY
       
      50 contracts
       
      250 contracts
       
      Not available
      AUD/CAD, AUD/JPY, AUD/NZD, CAD/JPY, CHF/JPY, EUR/AUD, EUR/CAD, EUR/NOK, EUR/SEK, GBP/JPY, GBP/CHF, NOK/USD, SEK/USD
      50 contracts
      Not available
      Not available
      Dow Jones CME FX$INDEX
      50 contracts
      Not available
      Not available
      Weather
      20 contracts
      20 contracts
      Not available
      Wood Pulp
      25 contracts
      25 contracts
      Not available
      Housing
      20 contracts
      20 contracts
      Not available
      U.S. Dollar Cash Settled Crude Palm Oil
      10 contracts
      Not available
      Not available
      Cheese
      20 contracts
      Not available
      Not available

       

      *      NOT applicable to E-mini or E-micro FX or E-mini equity indexes except those listed above.

       

      CBOT Products

       
              Futures
         Options
      Flex Options
      2-Year Treasury Notes (RTH)
      5,000 contracts**
      2,000 contracts
      Same as Non-Flex Options
       
      2-Year Treasury Notes (ETH)
      2,500 contracts**
      1,000 contracts
      Same as Non-Flex Options
       
      2-Year Treasury Notes (ATH)
      1,250 contracts**
      500 contracts
      Same as Non-Flex Options
       
      3-Year Treasury Notes (RTH)
      5,000 contracts**
      Not available
      Not available
       
      3-Year Treasury Notes (ETH)
      2,500 contracts**
      Not available
      Not available
       
      3-Year Treasury Notes (ATH)
      1,250 contracts**
      Not available
      Not available
       
      5- and 10-Year Treasury Notes (RTH)
      5,000 contracts**
      7,500 contracts
      Same as Non-Flex Options
       
      5- and 10-Year Treasury Notes (ETH)
      2,500 contracts**
      3,750 contracts
      Same as Non-Flex Options
       
      5- and 10-Year Treasury Notes (ATH)
      1,250 contracts**
      1,875 contracts
      Same as Non-Flex Options
       
      U.S. Treasury Bonds (RTH)
      3,000 contracts**
      7,500 contracts
      Same as Non-Flex Options
       
      U.S. Treasury Bonds (ETH)
      1,500 contracts**
      3,750 contracts
      Same as Non-Flex Options
       
      U.S. Treasury Bonds (ATH)
      750 contracts**
      1,875 contracts
      Same as Non-Flex Options
       
      Long-Term (Ultra) Treasury Bonds (RTH)
      2,000 contracts**
      Not available
      Not available
       
      Long-Term (Ultra) Treasury Bonds (ETH)
      1,500 contracts**
      Not available
      Not available
       
      Long-Term (Ultra) Treasury Bonds (ATH)
      750 contracts**
      Not available
      Not available
       
      2-, 5- and 10-Year OTR Treasury Yield (RTH)
      2,000 contracts**
      Not available
      Not available
       
      2-, 5- and 10-Year OTR Treasury Yield (ETH)
      1,000 contracts**
      Not available
      Not available
       
      2-, 5- and 10-Year OTR Treasury Yield (ATH)
      500 contracts**
      Not available
      Not available
       
      30-Day Fed Funds (RTH)
      2,000 contracts
      1,500 contracts
      Same as Non-Flex Options
       
      30-Day Fed Funds (ETH)
      1,000 contracts
      750 contracts
      Same as Non-Flex Options
       
      30-Day Fed Funds (ATH)
      500 contracts
      375 contracts
      Same as Non-Flex Options
       
      5-, 7-, 10- and 30-Year Interest Rate Swaps (RTH)
      2,000 contracts
      500 contracts
      Not available
       
      5-, 7-, 10- and 30-Year Interest Rate Swaps (ETH)
      1,000 contracts
      500 contracts
       
      Not available
       
       
      5-, 7-, 10- and 30-Year Interest Rate Swaps (ATH)
      500 contracts
      500 contracts
      Not available
       
      Dow Jones-UBS Commodity Index Excess Return
      300 contracts
      Not available
      Not available
       
      Dow Jones U.S. Real Estate Index
      50 contracts
      Not available
      Not available
       
      Ethanol
      10 contracts
      10 contracts
      Not available
       
      Distillers’ Dried Grain
      10 contracts
      Not available
      Not available
       

       

      **     Block trading of intra-commodity Treasury, OTR Treasury Yield and Interest Rate Swap futures calendar spreads is prohibited.
      11.        Contact Information
       
      Questions regarding this advisory may be directed to the following individuals:
       
      Market Regulation:         Colin Garvey, Lead Investigator                                     312.435.3656
                                          Robert Sniegowski, Rules & Regulatory Outreach            312.341.5991
                                          Erin Schwartz, Rules & Regulatory Outreach                   312.341.3083
       
      CME Clearing:               CME Clearing Support                                                   312.207.2525
       
      For media inquiries concerning this Advisory Notice, please contact CME Group Corporate Communications at 312.930.3434 or news@cmegroup.com.
       
      12.        Text of CME & CBOT Rule 526
       
       
      Rule 526               BLOCK TRADES
      The Exchange shall designate the products in which block trades shall be permitted and determine the minimum quantity thresholds for such transactions. The following shall govern block trades:
       
      A.       A block trade must be for a quantity that is at or in excess of the applicable minimum threshold.  Orders may not be aggregated in order to achieve the minimum transaction size, except by those entities described in Sections I. and J. 
       
      B.       Each party to a block trade must be an Eligible Contract Participant as that term is defined in Section 1a(12) of the Commodity Exchange Act.
       
      C.       A member shall not execute any order by means of a block trade for a customer unless such customer has specified that the order be executed as a block trade.
      D.       The price at which a block trade is executed must be fair and reasonable in light of (i) the size of the block trade, (ii) the prices and sizes of other transactions in the same contract at the relevant time, (iii) the prices and sizes of transactions in other relevant markets, including without limitation the underlying cash market or related futures markets, at the relevant time, and (iv) the circumstances of the markets or the parties to the block trade.
      E.       Block trades shall not set off conditional orders (e.g., Stop Orders and MIT Orders) or otherwise affect orders in the regular market.
      F.       CME - The seller must ensure that each block trade is reported to the Exchange within five minutes of the time of execution; except that block trades in interest rate futures and options executed outside of Regular Trading Hours (7:00 a.m. – 4:00 p.m. Central Time, Monday – Friday on regular business days) and Housing and Weather futures and options must be reported within fifteen minutes of the time of execution. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.
       
      F.       CBOT - The seller must ensure that each block trade is reported to the Exchange within five minutes of the time of execution; except that block trades in interest rate futures and options executed outside of Regular Trading Hours (7:00 a.m. – 4:00 p.m. Central Time, Monday – Friday on regular business days) must be reported within fifteen minutes of the time of execution. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.
      G.       Block trades must be reported to the Clearing House in accordance with an approved reporting method.
       
      H.       Clearing members and members involved in the execution of block trades must maintain a record of the transaction in accordance with Rule 536.
       
      I.         A commodity trading advisor ("CTA") registered or exempt from registration under the Act, including, without limitation, any investment advisor registered or exempt from registration under the Investment Advisors Act of 1940, shall be the applicable entity for purposes of Sections A., B., C., and D., provided such advisors have total assets under management exceeding $25 million and the block trade is suitable for the customers of such advisors.
       
      J.             A foreign Person performing a similar role or function to a CTA or investment advisor as described in Section I, and subject as such to foreign regulation, shall be the applicable entity for purposes of Sections A., B., C., and D., provided such Persons have total assets under management exceeding $25 million and the block trade is suitable for the customers of such Persons.

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