Block Trades and EFRPs in FuturesĬommodity Futures Trading Commission (CFTC) Rule 1.38 requires futures and options on futures to be executed by "open and competitive methods" – except where transactions are executed in a "noncompetitive" manner in compliance with designated contract market rules specifically providing for such noncompetitive execution. In addition, it offers some perspective on other futures trade practice issues that have been recent focus areas for US regulators. (IFUS), ICE Futures Europe (IFEU) and Cboe Futures Exchange (CFE). 1 This Advisory provides a high-level overview on this topic in connection with four principal derivatives exchange organizations: Chicago Mercantile Exchange Group (CME), ICE Futures U.S. With some frequency, Katten attorneys field questions from clients about exchange rules on off-exchange execution of futures and options on futures.
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