. . 

FINANCIAL INFORMATION SHARING 

MEMORANDUM OF UNDERSTANDING 

.ARTICLE l: GENERAL 

The United States Commodity Futures Trading Commis~ion 

{ "CF~C"), ·an independent ~egulatory agency of the u.s. govern..:. 

ment, the Securities and Investments Board ("SIB"), a "designated 

agency" to which statutory powers have been transferred under the 

Financial Services Act of 1986 {"FSA"} of the government of the 

United Kingdom and the self-regulatory organizations in the 

United States ("U.S. SROs"} and in the United Kingdom ("U.K. 

SROs"), as defined in Article II and subscribed hereto, have 

reached the follc\..riug understanding with respect to futures 

commission merchan-;;.s { "'l:'CMs") _tha<G ar~ applicants or designated 

_members, as defined in Article II. 

Section 50 of the FSA and parallel provisions in the 

Rulebooks of the U.K. SROs provide authority for the SIB or a 

U.K. SRO to waive app~ication of. those Financial Regulation Rules 

that deal with capital adequacy, __ where it finds that compliance 

would be unduly burdensome an.d ·wa:i,ver would not res~lt in undue 

risk to customers. As part of their responsibilities under the 

Conunodity Exchange Act ("CEA")_i. the CFTC and U.S. SROs monitor 

the capital ade·qu~cy of the afO.re~aid FcMs consistent with 

financial requirements promulgated under the CEA, and parallel 

financial requirements of the U.S. SROs, which have been approved 

by the CFTC. !n cons.l.derat-~_on of the:se responsibilities, the 

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applicability of such requirements and the understanding with 

respect to the exchange of information set forth below, the SIB 

and the U.K. SROs will not require designated member FCMs "to 

comply· with their r~sPect~ve capital adequacY requirements and 

any reporting standards relatiilg solely to the measure or 

maintenance of capital adequacy. This understanding does not 

prevent a party from requesting other information from a 

designated member or the other parties hereto. 

ARTICLE II: DEFINITIONS 

1. For purposes of this Financial Information Sharing 

Memorandum of Understanding ("FISMOU"): 

(a) "Applicant" means an FCM registered with the CFTC that 

is a member of a U.S. SRO that is a party to this 

FISMOU, that .is a person that has requested 

aUthorization from its relev"ant ·u.K·. regulator to 

establish a branch or to otherwise carry on an 

investment business in the United Kingdom ("U.K.") and 

that has r~quested that tho"se Financial Regulation 

Rules that deal with capital adequacy be waived by the 

SIB and the relevant U.K. SRO. In order to be an 

applicant, an FCM must complete three originals of a 

signed consent in the form_ of the consent annexed as 

E~hibit ·1 hereto and made a part, hereof, addressed to 

the releva.nt U.K. regulator, such FCM'"s designated U.S. 

SRO and the CFTC. 

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(b) "Designated member" means an FCM registered under the 

CEA that is a member of a U.S. SRO that is a party to 

this FISMOU, that has a branch or otherwise carries on 

an· investme_nt pusin_ess in ~.he u_.K.,. that is- an ·authorized or inter_im authorized person under the FSA for 

which tho~e Financia~ Regulation Rules that deal with 

capital adequacy have been waived by the SIB or the 

relevant U.K. regulator. In order to be a designated 

member, an FCM must complete three originals of a 

signed consent in the form of the consent annexed as 

Exhibit 1 hereto and made a part hereof, addressed to 

the relevant U.K. regulator, such FCM's designated U.S. 

SRO and the CFTC. 

(C) "Designated U.S. self--regulatory organization" or "des-

., ·ignated .u.s~ SRO." means a U.s. SRO that has primary 

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responsibility for examining a member FCM for 

compliance with minimum financial and related reporting 

requiremerits under CFTC overSight (i) pursuant to 

Section 4f(2) of the CEA and~ule 1.52 promulgated 

thereunder, and in a~cordance with a joint audit plan 

approved by the CFTC under. that rule, or (ii) because 

the member FCM is a member solely of that U.S. SRO. 

(d) ftForm 1-FR-FCM filing"_ means the financial report filed 

pursuant to Rule 1.10 under the CEA by an FCM on at 

least a semiannual basis-with its designated u.s. SRO. 

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·. ·. ., 
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··. 

(e) "Joint Audit Committee" means that certain committee of 

representatives of all U.S. SROs which was established 

to coordinate audit it.nd financial surveillance, plans, 

_poiicies and procedures, par~icularly with respect to 

FCMs that are members·of m,ore than Onf?- u.s. SRO. 

(f) "Relevant· U.K. regulate;" means (i) W~ere the FCM has 

been authorized under the FSA through membership in a 

single U.K. SRO, the U.K. SRO of which the FCM is a 

member, (ii) where the FCM has been authorized under 

the FSA through membership in more than one U.K. SRO, 

the U.K. SRO that the U.K. SROs have agreed should be 

the recipient of information under this FISMOU, or 

(iii) t~e SIB, where the FCM has been interim 

authorized or authorized by SIB under the FSA. 

(g) WRule 1.12 telegram" means the telegraphic or written 

notice .filed -by an FCM with its designated U.S. ·sRO and 

the CFTC pursuant to Rul.e 1.12 promulgated under the 

CEA if the FCM's {i) adjusted net capital falls below 

the minimum_required by an applicab~e.capital rule, 

(ii) adjusted net capital falls below 150 percent of 

the minimum required by an applicable c~Pital ru~e, 

(iii} books and records are not current, (iv) accounting system, accounting controls, procedures for safeguarding customer and firm assets or the practices and 

·procedUres specified in Rul~ 1.16{d) (l) promulgated 

under "the CEA,- ·contain a material inadequacy, as 

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defined in Rule 1.16(d)(2) promulgated under the CEA, 

or (v) carried accounts include an account which is 

undermargined by an amount which exceeds the firm's 

adjusted n~t·~~pital. 

(h) "U.S. self-regulatory organizati;on"' or "U.S. SRO" means 

the Board of ·Trade of ·t-he City of chicago, the Chicago 

Mercantile Exchange, the Commodity Exchange, Inc., New 

York Mercantile Exchange, National Futures Association 

or any other self-regulatory organization as defined in 

Rule 1.3(ee) promulgated under the CEA that becomes a 

party to this FISMOU in accordance with Article VII. 

(i) "U.K. self-regulating organisation" or "U.K. SRO" means 

the Association of Futures Brokers and Dealers, The 

Securities Association or any other self-regulating 

organisation that has been, reCogni·zed pursuant to 

Section 10 -of the FSA and is or becomes a party to this 

FIS~OU in accordance wit·h Article VII. 

ARTICLE III: EXCHANGE OF INFORMATION 

1. (a) Each U.S. SRO will provide 'to the relevant U.K. 

regulator, commencing with the first filing due after the 

effective date hereof as to that u.s. SRO, as promptly as 

practicable after receipt'of·the relevant report, the following 

information with respect to a designated member for which it is 

the designated u.s. SRO. 

(i) Copies of the cover sheet used by the u.s.- SRO in its 

. review of each Form 1.-FR-FCM filing. The U.S. SRO will 

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represent that it has reviewed the Form 1-FR-FCM filing 

and that, based solely on its review of the information 

in that filing, it has no reason to believe (oi it has 

.reason· to believe) that. there exists a viola~ion of the· 

minimum adjusted net capital.requirement set forth_ in 

Rule 1.17 promulgated under the CEA. The U.S. SRO also 

will provide a copy of the Form 1-FR-FCM upon request 

of the relevant U.K. regulator. 

(ii) Copies of Rule 1.12 telegrams. 

(iii) Notification if the designated member is classified as 

·high risk under the Joint Audit Committee criteria, 

~~ the ratio of customers' equities to the firm's 

adjusted net capital as calculated pursuant to the applicable capital rule exceeds 15 to 1. 

{b~ Each U.S. SRO will provide the relevant ·.U;.K .. regulator 

as promptly as practicable upon request the following information 

with respect to -aD applicant for which it is the designated U.S. 

SRO. 

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(i) Copies .of the cover sheet ~sed by the U.S. SRO in its 

review of the most recent .Form 1-FR-FCM filing. The 

U.S. SRO will repres·ent that the copy provided is the 

cover sheet with respect to the-most recent Form 

1-FR-FCM filing, that it has reviewed such filing and 

that, based solely on its ·review of the information in 

that filing, "it. has no reason to _believe (or it has 

reason to believe) that there eXists a violation of the 

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minimum adjusted net capital requirement set forth in 

Rule 1.17 promulgated under th"e CEA. The U.S. SRO will 

also provide a copy of the most recent Form 1-FR-FCM 

upon request pf the r.elevant U.R;. regUlator._ 

(ii) Copies of.Rule .1.12 telegr~s since.the •as of" date of 

the most recent l~FR-FCM filing. 

(iii) Notification if the applicant is classified 

as high risk under the Joint Audit Committee criteria, 

~' the ratio of customers' equities to the firm's 

adjusted net capital as calculated pursuant to the applicable capital rule exceeds 15 to 1. 

2. (a) Notwithstanding any other provision of this FISMOU, if 

information is provided by a u.s. SRO to the relevant U.K. 

regulator pursuant to paragraph l(a) of this Article III, such 

informati-on need ·not be provided by that u.·S. SRO to any other 

O.K. SRO or U.K. regUlator; provided further, however, that 

subject to Artic~e IV, such-U.K. SRO directly may furnish such 

information to another U.K. SRO or U.K. regulator. 

(b) If any relevant U.K. ·r~gulator agrees to indemnify any 

regulatory or self-regulatory authority in the United States or 

an_y other country -in connectiofl with -the· receipt of information 

or representations ·Similar _to that described in p-aragraphs 1 (a) 

or l(b) of this Article_ III, the relevant U.K. regulator must 

make such indemnity ar:rangement available to each u.s. SRO 

providing it with information under paragraphs l(a} or l(b) of 

this Article III. 

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3. (a} The CFTC will use its best efforts to notify the SIB if 

it becomes aware, through a U.S. SRO or otherwise, that an event 

has occurred that, in the sole judgment -of the CFTC, materially 

.and adversely ·affectS· the finanCial or operational 'viability of 

an applicant or a designated·member. . . . 

(b). ·The relevant U.K. ~eguli!!l~or will ase its_ best· efforts 

to notify and discuss with the CFTC if it becomes aware, through 

a U.K. SRO or otherwise, of a substantial financial, operational 

or other problem at a United Kingdom branch of, or as a result of 

investment business conducted in the U.K. by, a designated 

member. The CFTC may make information received pursuant to this 

paragraph available to a U.S. SRO. 

(c) The SIB or the relevant U.K. SRO will use its best 

efforts to notify and discuss with the CFTC if it becomes aware, 

through a_ u .• K. SRO or otherwise, ·of any -information .which in its 

respe~tive jud9'me_nt affects the. financial or operational 

viability of a .U.K.-domiciled firm doing business in the u.s. 

under a·comparability exemPtion granted pursuant to Rule 30.10 

promulgated under ~he CEA which may defer to the financial 

regulation ·rule~-· of the SIB ·and the relevan.t U.K. SRO. The CFTC 

may make information received pursuant t~ this paragraph 3(c) 

available to National Futures Association. 

4.. W_bere an indemnity, or Ot~er mutually acceptable 

arrangement-, for -protecting the exchange of information is in 

place between a.designated u.s. SRD and a relevant U.K. SRO, 

notification, infOnilation, and ·representations by the relevant 

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U.K. SRO under paragraphs 3(b) of this Article III, and 

notification and information as to an event which in a designated 

U.S. SRO's sole judgment materially and adversely affects.the 

f·illancial :or operational viability of an applicant or designated 

member also may .be exchanged directly between the designated u.s. . . 

·sRO and r.eleva.nt ·u;·K.· SRO. A copy of the applicable agreement 

will be provided to the CFTC by the designated U.S. SRO and to 

the SIB by the relevant U.K. SRO. 

5. Where SIB or a U.K. SRO intends to take action in relation 

to a designated member or an applicant on the basis of information supplied by the CFTC, or a designated U.S. SRO, pursuant to 

this FISMOU, SIB or such U.K. SRO, as appropriate, will to the 

_extent practicable give prior notice to the CFTC and the 

de~ignated U.S. SR04 

ARTICLE IV: CONFIDENTIALITY OF INFORMATION. 

·1. _(a} Each party to this FISMOU has advised the other parties of 

the rules, regulations and procedures·which govern the 

maintenance of confidentiality of information exchanged 

hereunder. Each .party will comply with ·its procedures for 

maintaining confidentiality and will advise ·the SIB or the CFTC 

.as appropriate of ·any changes therein. 

(b} EaCh par.ty to ·thiS FISMOU will keep confidential to the 

extent permitted by law any-information exchanged between the 

parties pursuant to this -FISMOU under Article III, provided that 

such information may be ·disclosed in appropriate circumstances in 

accordance with this FISMOU and otherwise under applicable law to 

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any person associated with or employed by the U.S. Congress, 

CFTC, SIB, Bank of England, the U.K. Department of Trade and 

Industry [Insurance Division] (U.K.), the Serious Fraud O-ffice 

(U.K.), Board of Governors of the Federal Reserve s·yst_em, u.·s. 

Department of the Tre~_sury, U.S. Department o~ Justice, U.S. 

·-secUrities a~d-Exchange Commission, U.S. Securities Investor 

Protection Corporation, a receiver, any agency of the federal 

government or of a state government in the U.S., U.S. 

self-regulatory organizations (as defined in Rule 1.3(ee) 

promulgated under the CEA) or U.K. self-regulating organisations 

. (that are recognized pursuant to Section 10 of the FSA) pursuant 

to their use for the purpose of: 

(i) secu~ing compliance with or enforcement of 01: conducting any investlgation relating to the statutes, rules 

and requirements -of the United S_tates or the United 

Kingdom or the rules of the U.S. self-regulatory 

organization .(as defined in Rule 1.3(ee) promulgated 

under the CEA) ·or U;K. self-regulating organisation 

{that is r~cognized pursuant to Section 10 of the FSA) 

or 

{ii) conducting a civil or -~dministrative enforcement or 

receivership prOceeding or other U.S. self-regulatory 

organization (as _defined in Rule 1.3(ee) promulgated 

under .the CEA) or U.K. self-regulating organisation 

(that is recognize.d pursuant t-o Section 10 of the FSA) 

disciplinary proceeding, assisting in a criminal 

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prosecution, or conducting any investigation related 

thereto for any possible violation related to the 

statutes, rules or requirements specified in 

subparagraph l(b) (i) of this ArUcle IV. 

(c) The SIB will keep confidential and will not disclose to 

· other parties_ to this FISMOU ·or otherw_ise any information 

received from the CFTC pursuant to this FISMOU under paragraph 

·., 

3(a) of Article III, provided that such information may be 

disclosed in connection with an adjudicatory action or proceeding 

brought under the laws of the U.K. or the rules and requirements 

of the SIB in the U.K. or the SIB is a party thereto or, provided 

further, that such information may be provided by the SIB to a 

U.K. SRO if applicable U.S. and U.K. law permits or if the 

designated member provides such consents to the CFTC and the SIB 

as may be legally effective to permit such disclosure. 

2. Except as _contemplated in paragraph l(b) of this Article IV, 

if any paity to this_ FISMOU :r:ec~iving information pursuant to 

this FISMOU becomes aware that such information has been received 

by any person that is not a party :to this FISMOU, it shall inform 

the party providing the information and will "thereafter use its 

best efforts to ensure that such information will not be used in 

any way that involves disclosure .not permitted-by this FISMOU. 

3. If a party which receives information pursuant to this FISMOU 

receives any legally-enforceable demand for such information, 

such party will to the best of its ability, prior to complying 

with the demand, promptly notify the party who provided such 

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information, and assert appropriate legal exemptions or 

privileges with respect to such information as may be available. 

4. Upon the execution o_f this F:tSMOU, the CFTC and the SIB will 

exchange li-sts _of the desi9nated members and a.pplicants and the 

designated U.S. SRO and relevant U.K. regulator with respect to 

each. Thereafter, the.SIB and CFTC.will .report any changes as to 

the relevant U.K. regulator and the designated U.S. SRO. When an 

applicant applies to a relevant U.K. regulator for a waiver of 

its financial regulation rules, the relevant U.K. regulator will 

advise the CFTC and the designated U.S. SRO reported by the 

applicant. The designated U.S. SRO will confirm in writing to 

the SIB its status as such. 

ARTICLE V: LIMITATIONS OF LIABILITY 

1. The parties to this FISMOU and their respective commissioners, directors, officers, employees or agents shall riot be liable 

to the other parties to this FISMOU and their respective commissioners, directors, officers, employees or agents for any liability, loss or damage resul.ting from or claimed to have resulted 

from any delays, inaccuracies, errors or omissions with respect 

to the provision of information or any representation regarding 

that information as provided hereby or the failure to provide any 

such information or representation. It is understood that the 

information is being supplied on a best efforts basis and no warranties, expressed or implied, are made by the parties with respect to the information to be furnished hereunder • 

" . . . 
... 

.·. 

2. The provisions of this FISMOU shall not give rise to the 

right on the part of any non-party to this FISMOU, directly or 

indirectly, to obtain any information or to challenge ·the execution of a request for infOrmation or the furnishing of. _any in.formation or representation under this_FISMOU.~ Nothing in this 

FISMOU- shall .entitle· .Any person, entity or government ~uthority 

to any rights as a third party beneficiary. 

ART!CLE V!: P!SPUTES AND CONSULTAT!ONS 

1. The parties will engage in consultations with respect to 

this FISMOU with a view to improving its operation and resolving 

any issues that may arise. The parties will also use their best 

efforts to notify each other of significant financial rule 

changes •. 

2. Except for the limitation on disclosure of information set 

:forth in· paragraph l(c) of Article IV of this FISMOU, any of the 

conditions Of this FISMOU may be amended, relaxed or waived by 

mutual agreement. of the CFTC, SIB, the relevant U.K. regulator 

and the designated U.S. SRO. Any such amendment, relaxation, or 

waiver shall be confirmed in writing among. the affected parties 

as soon as practicable. 

ART!CLE V!!: EXECUT!ON 

1. This"FISMOU will be effective from the date of its execution 

by the SIB, the CFTC and any U.S. SRO and relevant U.K. SRO; 

thereafter, it shall be effective as to each U.S. SRO or U.K. SRO 

fro.m the date 9f its execution by such u.s. SRO or U.K. SRO. 

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2. Any u.s. self-regulatory organization (as defined in Rule 

1.3(ee) promulgated under the CEA) or U.K. self-regulating 

organisation (that is recognized pursuant to Section 10 o·f the 

FS~) may become a party to this FISMOU by exec.uting a c:ounterpart 

hereof together with the CFTC and SIB and providing notice to the 

other f! .• s. SRO·s· anc:l U~K." SROs thereOf that are Parties to this 

FISMOU. The executed counterpart shall be deemed to be a part of 

the original FISMOU. 

ARTICLE VIII: CONTACT OFFICERS 

Information shall be exchanged pursuant to this FISMOU 

through the contact officers identified in Appendix A or their 

designees. 

ARTICLE IX: TERMINATION 

Any party may ·terminate its participation in this FISMOU 

provided it furnishes the other parties with-at least 120 days 

prior written notice. 

DATED this lst day of Sep., 1988 

United States Commodity 

Futures Trading Commission 

by ie/VJ 4 Y' 4 8 «>1m<>./ 

Board of Trade of the City 

of Chicago 

by ----------..,... 

Chicago Mercantile Exchange 

by----------

. · .. ·. ,_. ... __ . 

.• 

Securities and Investments 

Board 

by 

The Association -of Futures 

Brokers and Dealers Limited 

by 

The Securities Association 

Limited 

by 

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2. Any u.s. self-regulatory organization (as defined in Rule 

1.3(ee). ?rom~lgated under the CE~) or U.K. self-regulating 

orgarliSati~n· ·(that is· recOgi-lized pursuant to· Sec;tion 10· of the 

· FS_A) ·lXIaY be<:;:Qme· a party to.· this FISMOU by executing a _:_counterpart 

hereof together with the CFTC and ·srB and proViding not.ice to the 

other U.s. SROs and U.K. SROs thereof that are parties to this 

FISMOU. The executed counterpar~ shall be deemed to be a part of 

the original FISMOU. 

ARTICLE VIII: CONTACT OFFICERS 

Information shall be exchanged pursuant to this FISMOU 

through the contact officers identified in Appendix A or their 

designees. 

ARTICLE IX: TERMINATION 

Any party may terminate its participation in this FISMOU 

provided .it furnishes the other parties- with at least 120 days 

prior written notice. 

DATED ~his 1st day of Sep. 1988 

United States ·commodity· 

Futures Trading Commission 

·by ---------'-----

Board of Trade of the City 

of Chicago 

by ... 1L- . _; )C ~,. ~--

Chicago Mercantile.Exchan9e 

.SecuritieS arid Investments 

Board 

The Association of Futures 

Brokers and Dealers Limited 

by _________ _ 

·rhe Securities Association 

Limited 

by ..,...-~----..,...----

·.· .. 

.. I <::jPP 

i-/...,4( JV111{1. 
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2. Any U.S. self-regulatory organization (as defined in Rule 

L 3 (~e) promu.;t.ga1;:~~ under the CEA) .or. U.K. self-regulating . . . . ·. . . 

organ~~ation (that is re~ognized pursuant to Se9tion 10 of the 

FSA) may become· a party to this FISMbU by executing &_counterpart 

hereof together· with the _CfTC-:and 'SIB and pr9v:iding notice to the 

. . other u.s. SROs and U.K. SROs thereof that are parties to thiS 

FISMOU. The executed counterpart shall be deemed to be a part of 

the original FISMOU. 

ABT!CLE V!II: CONTACT OFF!CERS 

Information shall be exchanged pursuant to this FISMOU 

throu_gh the contact officers identified in Appendix A or their 

designees. 

ARTICLE !X: TERMINATION 

Any party may terminate .its participation in this FISMOU 

provided it fu::qlishes the other parties· wit'h at least 120 days 

pri_or written notice. 

DATED this 1st. day of Sep., "1988 

United States Commodity 

Futures Trading Commission 

by ,;_ ________ _ 

Board of Trade of .the City 

of ~hicago 

by ___ ~-------~--

ChicagO- Mercantile Exchange 

by-----~~---

·_, . 

.. ·· 

Securities and Investments 

:~ard~S' 

-The AssociatiOn of Futures 

Brokers and Dealers Limited 

by A:<. A·· · - · ...., . 

The Securities Association 

~~cmy'=='f 
Na.ional Futu s Association 

by ______ ~------------

.... 

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Investment Management 

Regulatory_Organisation Ltd. 

by 

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Commodity Exchange, Inc. 

by ----'---------

New- York .Mefcantiie_ ·exchange 

by -"""'"'---'------~-'---

National Futures Association·. 

by £1;,,>;(--)jt:,-. __ , 771 /?;o 

. -~ .. 

Investment Management 

Regulatory Organisation Ltd. 

by 
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Commodity Exchange, Inc. 

New YOrk MerCantile- ·E_xchange . · 

b~ ----------~------~ National Futures Association 

by ___ '-'--------~-----

Investment Management 

Regulatory Organisation Ltd. 

, by ~ ¥t· :¢4.11t\ ~ cv, 
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Commodity Exchange, Inc. 

by --------~--

New·York Mercantile Exchange. 

by -----------~-----

National Futures Association 

a-'Exchange - Inc. 

·. ,. 

Investment Management 

Regulatory Organisation Ltd. 

. by --------------'----

I 
Commodity Exchange, Inc. 

by----------

New York Mercantile Exchange 

by---'-~------~ 

Nati~nal Futures Association 

b . Y. -~~---'--'-,-----

.. . 

. . 

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; .. 

Investment Management 

Regulatory Organisation Ltd. 

by __________ _ 

.wtt.·· 

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Commodity Exchange, Inc. 

by----------

New York Mercantile Exchange 

by 

National Futures Association 

by----------

Coffee, Sugar & Cocoa Exchange Inc. 

by----------

. ~ 

New ~k Fu~u~ Exchan:r: Inc. 

by tt:.,-.._,, JLi,) D\1 tr 

Investment Management 

Regulatory Organisation Ltd. 

by